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...
Tds on payment of pest control charges - 194C or 194J - no material was brought on record by the Revenue to show that any technical services were availed by the assessee for doing pest control in its premises - AT
Tds on payment of pest control charges - 194C or 194J - no material was brought on record by the Revenue to show that any technical services were availed by the assessee for doing pest control in its premises - AT
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