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...
Leave fare concession payments for travel involving a foreign leg, made while an interim High Court order restrained tax deduction at source, did not attract assessee-in-default consequences under section 201(1). The Tribunal's approach followed a coordinate bench view that an employer-bank could not be treated as in default for failing to deduct tax during the restraint's operation. The employer-bank's appeal was allowed.
Leave fare concession payments for travel involving a foreign leg, made while an interim High Court order restrained tax deduction at source, did not attract assessee-in-default consequences under section 201(1). The Tribunal's approach followed a coordinate bench view that an employer-bank could not be treated as in default for failing to deduct tax during the restraint's operation. The employer-bank's appeal was allowed.
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