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 services - Joint venture - inclusion of "cost petroleum" and "profit petroleum" as per the Production sharing contract - inclusion of cash calls in the assessable value or not - Providing mining services to government - there is no service provider and service recipient relationship in the joint venture and the amounts in the nature of profit petroleum/cost petroleum/ cash calls are not consideration for services. - AT
Valuation of services - Joint venture - inclusion of "cost petroleum" and "profit petroleum" as per the Production sharing contract - inclusion of cash calls in the assessable value or not - Providing mining services to government - there is no service provider and service recipient relationship in the joint venture and the amounts in the nature of profit petroleum/cost petroleum/ cash calls are not consideration for services. - AT
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