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 royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee is not authorised to transfer, assign or convey the know how/technical information to any third party - payment was for mere use of technical know-how, not resulting in any enduring benefit - revenue exp.
Disallowance of royalty - capital OR revenue expenditure - The ownership/ proprietary rights in the technical know-how continue to vest in lithe censor and the assessee is not authorised to transfer, assign or convey the know how/technical information to any third party - payment was for mere use of technical know-how, not resulting in any enduring benefit - revenue exp.
Note: It is a system-generated summary and is for quick reference only.
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