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 - inclusion - there is no justification for including the value of free supplied materials while determining the gross amount charged for the purpose of benefit of Notification No.15/04-ST ibid as amended
Valuation - inclusion - there is no justification for including the value of free supplied materials while determining the gross amount charged for the purpose of benefit of Notification No.15/04-ST ibid as amended
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