Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Interest liability - merely because the credit is available in the books of account does not mean that the tax has been paid. Therefore, the liability to pay interest has to be computed from the due date of payment of tax to the actual date of payment - AT
Interest liability - merely because the credit is available in the books of account does not mean that the tax has been paid. Therefore, the liability to pay interest has to be computed from the due date of payment of tax to the actual date of payment - AT
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