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...
Import of services - certain reimbursements made to the foreign entities for the services received under Reverse Charge Mechanism - networking charges and technical services - The appellant argued that reimbursements for services performed outside India should not be taxed. The Tribunal agreed, referencing the Intercontinental Consultants & Technocrats case, which held that only the consideration for the taxable service should be valued and assessed, not additional expenses.
Import of services - certain reimbursements made to the foreign entities for the services received under Reverse Charge Mechanism - networking charges and technical services - The appellant argued that reimbursements for services performed outside India should not be taxed. The Tribunal agreed, referencing the Intercontinental Consultants & Technocrats case, which held that only the consideration for the taxable service should be valued and assessed, not additional expenses.
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