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...
Capital gain on transfer of shares outside India - For applicability of Explanation 5 of the section 9 it is sufficient to state that the explanation covers the non residents and not a resident entity - AT
Capital gain on transfer of shares outside India - For applicability of Explanation 5 of the section 9 it is sufficient to state that the explanation covers the non residents and not a resident entity - AT
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