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 of imported goods - related party transaction - the relationship did not influence the price - Rule 3(3)(a) & 3(3)(b) provide different means of establishing the acceptability of a transaction value - Rule 3(3)(b) cannot be made applicable while deciding the transaction value in the present case
Valuation of imported goods - related party transaction - the relationship did not influence the price - Rule 3(3)(a) & 3(3)(b) provide different means of establishing the acceptability of a transaction value - Rule 3(3)(b) cannot be made applicable while deciding the transaction value in the present case
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