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 import of goods - Additions of 2% Notional Commission on High Seas Sale - Purchased goods / Propane on High Seas Sale basis from various Public Sector undertaking like IOCL, BPCL, and HPCL. - on the basis of GATT guidelines and Section 14 of the Customs Act was amended in 2007, any inclusion of notional charges seems to have lost its relevance and only actual cost incurred by the buyer is required to be considered. - AT
Valuation of import of goods - Additions of 2% Notional Commission on High Seas Sale - Purchased goods / Propane on High Seas Sale basis from various Public Sector undertaking like IOCL, BPCL, and HPCL. - on the basis of GATT guidelines and Section 14 of the Customs Act was amended in 2007, any inclusion of notional charges seems to have lost its relevance and only actual cost incurred by the buyer is required to be considered. - AT
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