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 - Manpower Recruitment Agency Service - conversion of raw material to soap and detergent on behalf of the principal - contract between the appellant and M/s Nirma Limited is of contract manufacturing hence demand under manpower supply cannot be made. - AT
Classification of services - Manpower Recruitment Agency Service - conversion of raw material to soap and detergent on behalf of the principal - contract between the appellant and M/s Nirma Limited is of contract manufacturing hence demand under manpower supply cannot be made. - AT
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