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...
Monetary amount involved in the appeal - We have here a situation where the Revenue's advocate seeks to disown the Circular and seeks to brush it aside in this case. If such a tend is allowed, in future every matter filed by the Revenue will chart the same course. In every case, the Revenue proposes certain questions and terms them as substantial questions of law.
Monetary amount involved in the appeal - We have here a situation where the Revenue's advocate seeks to disown the Circular and seeks to brush it aside in this case. If such a tend is allowed, in future every matter filed by the Revenue will chart the same course. In every case, the Revenue proposes certain questions and terms them as substantial questions of law.
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