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...
Royalty/fees for technical services u/s. 9 (1) (vi)/9 (1)(vii) - payment made by SCB to assessee company does not fall within the realm of “fees for technical services‟ as contained in Sec. 9(1)(vii), albeit the assessee has only provided a standard facility for data processing without any human intervention - AT
Royalty/fees for technical services u/s. 9 (1) (vi)/9 (1)(vii) - payment made by SCB to assessee company does not fall within the realm of “fees for technical services‟ as contained in Sec. 9(1)(vii), albeit the assessee has only provided a standard facility for data processing without any human intervention - AT
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