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...
Profiteering - supply of “Services by way of admission to exhibition of cinematograph films” - allegation that the benefit of reduction in the rate of tax not passed on by way of commensurate reduction in price - The mathematical methodology employed by the DGAP to compute the profiteered amount is correct, appropriate, reasonable and in consonance with the provisions of Section 171(1) - NAPA
Profiteering - supply of “Services by way of admission to exhibition of cinematograph films” - allegation that the benefit of reduction in the rate of tax not passed on by way of commensurate reduction in price - The mathematical methodology employed by the DGAP to compute the profiteered amount is correct, appropriate, reasonable and in consonance with the provisions of Section 171(1) - NAPA
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