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...
Valuation of imported goods - NIDB data of contemporaneous imports - The only thing established during the investigation is that other importers imported goods through Nhava Sheva port at different prices and the difference in quantities was between 3 times to 500 times. This does not in any way prove that the declared transaction value was not true or not accurate. - AT
Valuation of imported goods - NIDB data of contemporaneous imports - The only thing established during the investigation is that other importers imported goods through Nhava Sheva port at different prices and the difference in quantities was between 3 times to 500 times. This does not in any way prove that the declared transaction value was not true or not accurate. - AT
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