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...
Accrual of income in India u/s 5(2) - Foreign allowances on account of the international assignment - assessee was an employee in IBM India Private Limited and during the financial year 2012-13 was sent on short term assignment to Switzerland. - exemption in respect of foreign assignment allowance allowed.
Accrual of income in India u/s 5(2) - Foreign allowances on account of the international assignment - assessee was an employee in IBM India Private Limited and during the financial year 2012-13 was sent on short term assignment to Switzerland. - exemption in respect of foreign assignment allowance allowed.
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