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...
Commercial training or coaching services - Place of supply of services - The services covered under the said sub-Rule is taxable only when the same are performed in India. In the instance case, it is not in dispute that the said service was performed outside of India. Therefore, there cannot be any liability of tax.
Commercial training or coaching services - Place of supply of services - The services covered under the said sub-Rule is taxable only when the same are performed in India. In the instance case, it is not in dispute that the said service was performed outside of India. Therefore, there cannot be any liability of tax.
Note: It is a system-generated summary and is for quick reference only.