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...
Valuation - Physician Samples - the sales are to industrial consumers and are not sold / supplied to retail consumers. By this logic also, the provisions of Section 4A are not applicable in the facts of the case.
Valuation - Physician Samples - the sales are to industrial consumers and are not sold / supplied to retail consumers. By this logic also, the provisions of Section 4A are not applicable in the facts of the case.
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