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...
Royality u/s 9 - Addition in respect of license fee for live and non-live transmission qua Sony Pictures Networks India Pvt.Ltd. - In the absence of any corresponding change into DTAA in terms, ratio laid down in New Skies Satellite BV (Supra) the amended provision of section 9 of the Act, would have no application. - AT
Royality u/s 9 - Addition in respect of license fee for live and non-live transmission qua Sony Pictures Networks India Pvt.Ltd. - In the absence of any corresponding change into DTAA in terms, ratio laid down in New Skies Satellite BV (Supra) the amended provision of section 9 of the Act, would have no application. - AT
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