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...
Payment of Non-compete fees - revenue expenditure vs capital expenditure - Said payment was made for the purpose of running the business and not for the purpose of acquiring the business. - held as revenue in nature - AT
Payment of Non-compete fees - revenue expenditure vs capital expenditure - Said payment was made for the purpose of running the business and not for the purpose of acquiring the business. - held as revenue in nature - AT
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