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...
Import of services - reverse charge - amount paid as insurance premium by the appellant to TD Bank as part of loan amount - borrower of money in India is neither a service provider nor service recipient in connection with insurance taken by the lender. - AT
Import of services - reverse charge - amount paid as insurance premium by the appellant to TD Bank as part of loan amount - borrower of money in India is neither a service provider nor service recipient in connection with insurance taken by the lender. - AT
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