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...
Non-deduction of TDS u/s 195 - expenses incurred by the assessee to International Project Services Oy. (IPS) - Since the relevant information for ascertaining the duration of stay of such residents of Finland in India is not available on record, matter remanded back - AT
Non-deduction of TDS u/s 195 - expenses incurred by the assessee to International Project Services Oy. (IPS) - Since the relevant information for ascertaining the duration of stay of such residents of Finland in India is not available on record, matter remanded back - AT
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