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...
Assessable / Transaction Value – inclusion of Cost of Pre Delivery Inspection (PDI) and Free after sales services - circulars, is contrary to Section 4(3)(d), liable to be quashed and set aside - HC
Assessable / Transaction Value – inclusion of Cost of Pre Delivery Inspection (PDI) and Free after sales services - circulars, is contrary to Section 4(3)(d), liable to be quashed and set aside - HC
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