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...
TDS on fees for technical services - When a particular technology was made available to the assessee by Xennia exclusively, it cannot be said that the agreement was only for sale of printer. - AT
TDS on fees for technical services - When a particular technology was made available to the assessee by Xennia exclusively, it cannot be said that the agreement was only for sale of printer. - AT
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