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...
Manufacture - appellants have assembled the kit of bought out items - Chapter 85/87 - the activity of packing of various parts into small retail packing and sale thereof to various customers does not fall under the purview of manufacture. - AT
Manufacture - appellants have assembled the kit of bought out items - Chapter 85/87 - the activity of packing of various parts into small retail packing and sale thereof to various customers does not fall under the purview of manufacture. - AT
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