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...
Valuation - rejection of transaction value - Mere presence of the CHA at the time of examination does not mean that the copy of the third chartered engineer report was provided to the respondent and it is clear that they were not given a chance to rebut the same. - AT
Valuation - rejection of transaction value - Mere presence of the CHA at the time of examination does not mean that the copy of the third chartered engineer report was provided to the respondent and it is clear that they were not given a chance to rebut the same. - AT
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