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...
Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on record by the Revenue to suggest that the transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis
Disallowance of notional interest under TP - TPO had re-characterised the transaction of subscription of shares into advancing of unsecured loans - Nothing is brought on record by the Revenue to suggest that the transaction was sham - TPO could not have treated such transaction as a loan and charged interest thereon on notional basis
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
