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...
Scientific and Technical Consultancy Service - In-house training M/s SMC, Japan does not covered under Scientific and Technical Consultancy Service in terms of Section 65 (95a) of the Finance Act, 1994 - the appellant is not liable to pay interest for the intervening period i.e. date of service provided till its realization. - AT
Scientific and Technical Consultancy Service - In-house training M/s SMC, Japan does not covered under Scientific and Technical Consultancy Service in terms of Section 65 (95a) of the Finance Act, 1994 - the appellant is not liable to pay interest for the intervening period i.e. date of service provided till its realization. - AT
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