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 on accrual of income - deferred revenue - royalty - The rights of the TV Serial were to come back to the assessee after a period of 6 years - AS-9 allows deferment of royalty income - assessee had rightly offered the incomes in six AY.s - AT
Addition on accrual of income - deferred revenue - royalty - The rights of the TV Serial were to come back to the assessee after a period of 6 years - AS-9 allows deferment of royalty income - assessee had rightly offered the incomes in six AY.s - AT
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