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...
Valuation - goods valued on the ex-factory value - supply of goods was on FOR basis - only possible criteria for the purpose is as to whether the property in goods stands transferred to the buyer at the time when the goods are cleared at manufacturer place or not - dept. has been acknowledged that all the verifications, approvals by buyer got conducted at factory itself - assessable without freight and insurance
Valuation - goods valued on the ex-factory value - supply of goods was on FOR basis - only possible criteria for the purpose is as to whether the property in goods stands transferred to the buyer at the time when the goods are cleared at manufacturer place or not - dept. has been acknowledged that all the verifications, approvals by buyer got conducted at factory itself - assessable without freight and insurance
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