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...
The branch office in India was treated as a continuation of the earlier liaison office, because the RBI approval and the nature of the upgraded arrangement showed an enlarged continuation of the existing presence rather than a new setup. On that basis, the Tribunal recorded that the branch office constituted a permanent establishment in India. As the taxability and profit attribution issues for the year were similar to those already remanded in earlier years, the matter was restored to the Assessing Officer for de novo examination, including the assessee's claim that the branch office served only the machinery division.
The branch office in India was treated as a continuation of the earlier liaison office, because the RBI approval and the nature of the upgraded arrangement showed an enlarged continuation of the existing presence rather than a new setup. On that basis, the Tribunal recorded that the branch office constituted a permanent establishment in India. As the taxability and profit attribution issues for the year were similar to those already remanded in earlier years, the matter was restored to the Assessing Officer for de novo examination, including the assessee's claim that the branch office served only the machinery division.
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