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 - inclusion of cost of design and drawing - The drawings supplied by the customers being only dimensions of the components could therefore have no value - there is no justification to hold that the cost of drawings supplied by the customers is required to be included in the assessable value of the final product.
Valuation - inclusion of cost of design and drawing - The drawings supplied by the customers being only dimensions of the components could therefore have no value - there is no justification to hold that the cost of drawings supplied by the customers is required to be included in the assessable value of the final product.
Note: It is a system-generated summary and is for quick reference only.
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