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...
Renting of Immovable Property Services or not - assignment of entire business of the hotel to IHCL - there is no “fixed rent” that is payable as would be expected in a normal renting of immovable property transaction - Demand set aside.
Renting of Immovable Property Services or not - assignment of entire business of the hotel to IHCL - there is no “fixed rent” that is payable as would be expected in a normal renting of immovable property transaction - Demand set aside.
Note: It is a system-generated summary and is for quick reference only.