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...
Classification of services - reverse charge mechanism - salary paid to employees deputed to the appellant by their parent company for assisting them in their business operations of software development and information technology and other related support service - Cannot be held as Manpower Recruitment or Supply Agency Service - AT
Classification of services - reverse charge mechanism - salary paid to employees deputed to the appellant by their parent company for assisting them in their business operations of software development and information technology and other related support service - Cannot be held as Manpower Recruitment or Supply Agency Service - AT
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