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 - receipt of bonus by the service provider for efficient use of diesel and explosives - this amount was not known at the time of provision of services - This amount cannot be included as value of taxable services rendered u/s 67.
Valuation - receipt of bonus by the service provider for efficient use of diesel and explosives - this amount was not known at the time of provision of services - This amount cannot be included as value of taxable services rendered u/s 67.
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