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 192 - Payment of salary by transfer to UP Cooperative Union for deputed persons / supervisors - TDS was deductible and since it was not done by the assessee, the disallowance made by Assessing Officer and confirmed by CIT(A) is proper - AT
TDS u/s 192 - Payment of salary by transfer to UP Cooperative Union for deputed persons / supervisors - TDS was deductible and since it was not done by the assessee, the disallowance made by Assessing Officer and confirmed by CIT(A) is proper - AT
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