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...
Addition u/s 37(1) - processing fees - the payment has not been made for acquiring a brand name, but for facilitating for acquisition of the brand name - by applying positive and negative tests, it is found that the expenditure is revenue in Nature - AT
Addition u/s 37(1) - processing fees - the payment has not been made for acquiring a brand name, but for facilitating for acquisition of the brand name - by applying positive and negative tests, it is found that the expenditure is revenue in Nature - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
