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...
Accrual of income in India - royalty receipt - transmission of ‘live feed’ - Income from the transmission of 'live feed' does not fall within the ambit of 'royalty' under Section 9(1)(vi) of the Income Tax Act, as per the interpretation of what constitutes 'work' under the Copyright Act. - HC
Accrual of income in India - royalty receipt - transmission of ‘live feed’ - Income from the transmission of 'live feed' does not fall within the ambit of 'royalty' under Section 9(1)(vi) of the Income Tax Act, as per the interpretation of what constitutes 'work' under the Copyright Act. - HC
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