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...
Classification of services - Manpower Recruitment/Supply service - the contract is for handling the agricultural produce which is a Work Order though the payment has been made on the strength of man-days provided and not for supplying the manpower service - demand on the said service is set-aside along with penalty and interest
Classification of services - Manpower Recruitment/Supply service - the contract is for handling the agricultural produce which is a Work Order though the payment has been made on the strength of man-days provided and not for supplying the manpower service - demand on the said service is set-aside along with penalty and interest
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