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...
Transfer of right to use goods - Hiring of Charter Vessel for dredging activity -Appellant enjoys full right to exclusion of others. During the period, neither the owner can use the vessel nor can the owner transfer the right to use of the vessel to another person - there exist no hesitation to hold that the appellant enjoys right to use the vessel to the exclusion of the owner.
Transfer of right to use goods - Hiring of Charter Vessel for dredging activity -Appellant enjoys full right to exclusion of others. During the period, neither the owner can use the vessel nor can the owner transfer the right to use of the vessel to another person - there exist no hesitation to hold that the appellant enjoys right to use the vessel to the exclusion of the owner.
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