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...
TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid
TP Adjustment - ALP of the royalty paid AE - royalty paid by other group entities are controlled transactions whereas, rule 10B(1)(a) mandates that the price charged for an uncontrolled transaction/transaction should be considered as a CUP - the determination of arm's length price as approved by the RBI/SIA is valid
Note: It is a system-generated summary and is for quick reference only.
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