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...
Tax deduction at source on foreign-travel leave fare concession was not required where judicial interim directions prevented the employer-bank from making the deduction. The bank had sufficient and reasonable cause because it could not lawfully act contrary to those directions. Consequently, the conditions for treating it as an assessee in default and imposing consequential interest for non-deduction were not met. The demand raised for default and interest was cancelled, and the bank was not liable for the impugned non-deduction during the subsistence of the interim directions.
Tax deduction at source on foreign-travel leave fare concession was not required where judicial interim directions prevented the employer-bank from making the deduction. The bank had sufficient and reasonable cause because it could not lawfully act contrary to those directions. Consequently, the conditions for treating it as an assessee in default and imposing consequential interest for non-deduction were not met. The demand raised for default and interest was cancelled, and the bank was not liable for the impugned non-deduction during the subsistence of the interim directions.
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