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...
Purchase of computer software - Capital v/s Revenue - the license fees paid was for renewal of the usage of software and for a limited period for less than two years thus held to be in nature of revenue - AT
Purchase of computer software - Capital v/s Revenue - the license fees paid was for renewal of the usage of software and for a limited period for less than two years thus held to be in nature of revenue - AT
Note: It is a system-generated summary and is for quick reference only.
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