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...
Alleged training of employees outside India as well as in India through availing services of parent company - demand imposed under the reverse charge mechanism for the services availed from foreign service provider - AT
Alleged training of employees outside India as well as in India through availing services of parent company - demand imposed under the reverse charge mechanism for the services availed from foreign service provider - AT
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