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...
DTAA - Retrospective amendments under consideration do not impact interpretation in the context of a DTAA also the Finance Minister’s speech on 7 May 2012 wherein it was clarified that the amendments do not override the provisions of a DTAA which India has signed. - HC
DTAA - Retrospective amendments under consideration do not impact interpretation in the context of a DTAA also the Finance Minister’s speech on 7 May 2012 wherein it was clarified that the amendments do not override the provisions of a DTAA which India has signed. - HC
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