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...
Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT
Higher rate of TDS @20% for non-furnishing of PAN u/s 206AA - whether cannot be at a rate prescribed u/s 206AA which is higher than the rate at which the relevant income is chargeable to tax under Act or DTAA - the scope of deduction of tax at source cannot be more than the tax liability under DTAA. - AT
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