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...
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
Business Auxiliary Services - promotion or marketing of goods produced or provided by or belonging to the client - transfer of right to use - The imposition of restrictions or conditions in respect of the usage and consumption of the concentrate, by the seller cannot alter that position. Hence there are no merit in the submission that this transaction was not a truncation of sale but only “transfer to use”. - AT
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