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...
Maintenance or repair service - inasmuch as the appellant was reflecting everything in their returns filed with the Revenue, no malafide can be attributed to them - The activity of re-conditioning of old and worn out sugar mills rollers would not be taxable prior to 16.06.2005
Maintenance or repair service - inasmuch as the appellant was reflecting everything in their returns filed with the Revenue, no malafide can be attributed to them - The activity of re-conditioning of old and worn out sugar mills rollers would not be taxable prior to 16.06.2005
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