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...
India UAE DTAA - Whether the consideration received by the applicant has to be deemed to be “royalty‟ under section 9(1)(vi) - as the Revenue itself in its objection suggested that the consideration received would be fees for technical services to be dealt with as such in this state it no ruling on this question required. - AAR
India UAE DTAA - Whether the consideration received by the applicant has to be deemed to be “royalty‟ under section 9(1)(vi) - as the Revenue itself in its objection suggested that the consideration received would be fees for technical services to be dealt with as such in this state it no ruling on this question required. - AAR
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