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...
Levy of Tax - Stock Transfer of Goods - the Form 'F' would not be considered conclusive proof of Stock Transfer - the burden to prove that the transaction was of transfer of goods otherwise than by way of Sale was on the Revisionist-dealer.
Levy of Tax - Stock Transfer of Goods - the Form 'F' would not be considered conclusive proof of Stock Transfer - the burden to prove that the transaction was of transfer of goods otherwise than by way of Sale was on the Revisionist-dealer.
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