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 activity - manufacture or service - making of photo books/albums, calendars, brochures etc. to their different customers - The Tribunal concurred with the assessee's contention that their activity constitutes 'manufacture' rather than a taxable service. They noted that the process undertaken by the assessee involves significant transformation and results in the creation of new commercial products.
Nature of activity - manufacture or service - making of photo books/albums, calendars, brochures etc. to their different customers - The Tribunal concurred with the assessee's contention that their activity constitutes 'manufacture' rather than a taxable service. They noted that the process undertaken by the assessee involves significant transformation and results in the creation of new commercial products.
Note: It is a system-generated summary and is for quick reference only.
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