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 - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
Valuation - related person or not - a proprietorship concern and a Private Limited company are not related person - even if two are held to be related, the price to any independent buyer of similar quantity only can be adopted under Rule 11 - Demand fails on both count.
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