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...
Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions made by AO deleted - AO directed to attribute 1% of the receipts from offshore supply of equipment as profit of the PE and accordingly compute the income of the assessee. - AT
Attribution of profit to PE qua the offshore supply of plants and equipments - Attribution of profit to PE qua the offshore supply of plants and equipments - Additions made by AO deleted - AO directed to attribute 1% of the receipts from offshore supply of equipment as profit of the PE and accordingly compute the income of the assessee. - AT
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