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...
Permanent Establishment(PE) - if in vacation period, employee has not rendered any services in India, that period should not be included for counting 90 days stay - multiple counting of employees in a single day not permissible - No PE - fee for legal consultancy services is not taxable in India
Permanent Establishment(PE) - if in vacation period, employee has not rendered any services in India, that period should not be included for counting 90 days stay - multiple counting of employees in a single day not permissible - No PE - fee for legal consultancy services is not taxable in India
Note: It is a system-generated summary and is for quick reference only.