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...
Method of Valuation - Transaction value or MRP value - sale of mineral water to PVRs (Cinema halls) who are institutional consumers - there is no question of the applicability of Section 4 - appellant has discharged duty u/s 4A (MRP based) rightly.
Method of Valuation - Transaction value or MRP value - sale of mineral water to PVRs (Cinema halls) who are institutional consumers - there is no question of the applicability of Section 4 - appellant has discharged duty u/s 4A (MRP based) rightly.
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