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...
Withholding tax on payment of legal representation charges to Simpson & Grierson, New Zealand - assessee has to prove that the services were rendered outside India and the same was utilized outside India and the payee is having no business or business connection in India. - AT
Withholding tax on payment of legal representation charges to Simpson & Grierson, New Zealand - assessee has to prove that the services were rendered outside India and the same was utilized outside India and the payee is having no business or business connection in India. - AT
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