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...
TP adjustment of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside the purview of TP mechanism but at time of claiming depreciation it is relevant otherwise same will be allowed only on revised value.
TP adjustment of Technical Assistance fees and project management services not claimed as expenditure but capitalized as project - capital transactions are outside the purview of TP mechanism but at time of claiming depreciation it is relevant otherwise same will be allowed only on revised value.
Note: It is a system-generated summary and is for quick reference only.
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