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...
Taxability on the Settlement Amount payable under the Stipulation pursuant to the judgment and Final approval of the US Court - applicant is required to deduct income-tax @ 30% when the settlement amount moves from the segregated account to the initial escrow account. - AAR
Taxability on the Settlement Amount payable under the Stipulation pursuant to the judgment and Final approval of the US Court - applicant is required to deduct income-tax @ 30% when the settlement amount moves from the segregated account to the initial escrow account. - AAR
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