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...
Trusts or institutions not filing the application in certain cases - Trust or institutions under first or second regime shall have to apply for re-registration in case of failure such trust or institutions will become ineligible for any exemption thereunder and therefor they have to pay tax on accreted income on MMR basis u/s 115TD. Provisions of section 115TD has been amended as to provide for certain conditions for application for re-registration.
Trusts or institutions not filing the application in certain cases - Trust or institutions under first or second regime shall have to apply for re-registration in case of failure such trust or institutions will become ineligible for any exemption thereunder and therefor they have to pay tax on accreted income on MMR basis u/s 115TD. Provisions of section 115TD has been amended as to provide for certain conditions for application for re-registration.
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