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...
Income accrued in India - Centralized services fee received - royalty or fee for technical services The payments received were rightly held by the Tribunal, to be in the nature of business income. And since the assessee admittedly does not have a permanent establishment under the article 7 of the D TAA 'business income' received by the assessee cannot be brought to tax in India. - AT
Income accrued in India - Centralized services fee received - royalty or fee for technical services The payments received were rightly held by the Tribunal, to be in the nature of business income. And since the assessee admittedly does not have a permanent establishment under the article 7 of the D TAA 'business income' received by the assessee cannot be brought to tax in India. - AT
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