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...
Disallowance u/s 40(a)(ia) of the Act - Reimbursement of CHA charges paid to C & F agent – No requirement to deduct TDS on reimbursement of transportation charges to the agent - HC
Disallowance u/s 40(a)(ia) of the Act - Reimbursement of CHA charges paid to C & F agent – No requirement to deduct TDS on reimbursement of transportation charges to the agent - HC
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