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...
Software expenses - revenue v/s capital - expenditure incurred are not capital expenditure as due to technological changes and the need to upgrade the software on a regular basis it cannot be said that the software was of an enduring nature - HC
Software expenses - revenue v/s capital - expenditure incurred are not capital expenditure as due to technological changes and the need to upgrade the software on a regular basis it cannot be said that the software was of an enduring nature - HC
Note: It is a system-generated summary and is for quick reference only.
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