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...
Nature of subsidy received under the Technology Upgradation Fund Scheme - revenue or capital receipt - The subsidy was clearly for the purpose of upgrading the machinery and plant and for acquiring capital assets - Cannot be taxed as revenue receipt.
Nature of subsidy received under the Technology Upgradation Fund Scheme - revenue or capital receipt - The subsidy was clearly for the purpose of upgrading the machinery and plant and for acquiring capital assets - Cannot be taxed as revenue receipt.
Note: It is a system-generated summary and is for quick reference only.
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