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 u/s 194 - Deemed dividend u/s 2(22)(e) - when the loans/advances have been given to a non shareholder, then it is impossible for a payer company to ascertain whether it will attract the provisions of section 2(22)(e) or not - provisions of section 2(22)(e) and 194 do not require the payer assessee company to deduct TDS u/s 194 - AT
TDS u/s 194 - Deemed dividend u/s 2(22)(e) - when the loans/advances have been given to a non shareholder, then it is impossible for a payer company to ascertain whether it will attract the provisions of section 2(22)(e) or not - provisions of section 2(22)(e) and 194 do not require the payer assessee company to deduct TDS u/s 194 - AT
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