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 194C - payment made by the assessee towards freight to Forwarding and Clearing Agents - non deduction of TDS u/s.40(a)(ia) - The Assessee cannot break-up the said bill into reimbursement and charges. - AT
TDS u/s 194C - payment made by the assessee towards freight to Forwarding and Clearing Agents - non deduction of TDS u/s.40(a)(ia) - The Assessee cannot break-up the said bill into reimbursement and charges. - AT
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