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...
Undisclosed income - CBEC has not accepted the invoice value and determined separate value for the purpose of customs duty. Therefore, merely for the reason that the CBEC does not accept the value declared by the assessee, it does not mean that the assessee has understated the imports and difference between actual price paid for imports and value determined by the CBEC is undisclosed income of the assessee. - AT
Undisclosed income - CBEC has not accepted the invoice value and determined separate value for the purpose of customs duty. Therefore, merely for the reason that the CBEC does not accept the value declared by the assessee, it does not mean that the assessee has understated the imports and difference between actual price paid for imports and value determined by the CBEC is undisclosed income of the assessee. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
