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...
Nature of expenses - payment of royalty - revenue or capital expenditure - Permission to user the name and Trade Mark - Royalty is payable on the basis of Annual Sales Turnover - No new asset was acquired by the assessee. The assessee merely acted as user. - CIT(A) rightly allowed the same as revenue expenditure - AT
Nature of expenses - payment of royalty - revenue or capital expenditure - Permission to user the name and Trade Mark - Royalty is payable on the basis of Annual Sales Turnover - No new asset was acquired by the assessee. The assessee merely acted as user. - CIT(A) rightly allowed the same as revenue expenditure - AT
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