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...
Transfer of the 74% shares to the Singapore company - transactions were part of a design of 'treaty shopping' as having regard to the DTAA between India and Singapore, the capital gain would only be taxed at Singapore and not in India. - HC
Transfer of the 74% shares to the Singapore company - transactions were part of a design of 'treaty shopping' as having regard to the DTAA between India and Singapore, the capital gain would only be taxed at Singapore and not in India. - HC
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