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...
TP Adjustment - MAM selection - brokerage service income - CUP v/s TNMM - the transactional net margin method is the most appropriate method for determination of the arm’s-length price of the brokerage service income earned by the assessee. - AT
TP Adjustment - MAM selection - brokerage service income - CUP v/s TNMM - the transactional net margin method is the most appropriate method for determination of the arm’s-length price of the brokerage service income earned by the assessee. - AT
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