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...
Services in relation to digital signature certificates (DSC) - Sub Certifying authorities - mere act of collecting the applications and verification of the same for onward submission to the appellant cannot be termed as “grant of representational rights” - Cannot be held as Franchisee Service.
Services in relation to digital signature certificates (DSC) - Sub Certifying authorities - mere act of collecting the applications and verification of the same for onward submission to the appellant cannot be termed as “grant of representational rights” - Cannot be held as Franchisee Service.
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