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...
Management Fees paid to its holding company - once assessee had established its case of availment of said services, disallowance on the basis that invoices were serially numbered and paid at the close of the year is not permissible
Management Fees paid to its holding company - once assessee had established its case of availment of said services, disallowance on the basis that invoices were serially numbered and paid at the close of the year is not permissible
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