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...
The words "adopted" or "assessed" (as also "assessable") in s. 50C(1) qualify the word "value" preceding it, and not the word "transfer" - there being no assessment by it by the end of the relevant year, i.e., 31-03-2006 cannot be accepted - AT
The words "adopted" or "assessed" (as also "assessable") in s. 50C(1) qualify the word "value" preceding it, and not the word "transfer" - there being no assessment by it by the end of the relevant year, i.e., 31-03-2006 cannot be accepted - AT
Note: It is a system-generated summary and is for quick reference only.