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...
Extended period of limitation - From the facts as available on record specifically the correspondences with CBEC, the issue involved in those correspondences were in relation to Central Depository Services and not in relation to services of providing for “provision and transfer of information and data processing”. - Demand confirmed invoking the extended period of limitation.
Extended period of limitation - From the facts as available on record specifically the correspondences with CBEC, the issue involved in those correspondences were in relation to Central Depository Services and not in relation to services of providing for “provision and transfer of information and data processing”. - Demand confirmed invoking the extended period of limitation.
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