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...
DTAC between India and USA - secondment of the employees by the U.S. Principal - the same is income in hands of US Principal subject to withholding of taxes u/s 195 - AAR
DTAC between India and USA - secondment of the employees by the U.S. Principal - the same is income in hands of US Principal subject to withholding of taxes u/s 195 - AAR
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