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 194H - whether expenditure towards “Authority to Guarantee charges” falls within the ambit of section 194H or not?- Held no - The requirement of an agent and principal relationship is found absent in this case - AT
TDS u/s 194H - whether expenditure towards “Authority to Guarantee charges” falls within the ambit of section 194H or not?- Held no - The requirement of an agent and principal relationship is found absent in this case - AT
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