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 tax at source in respect of interest on debenture u/s 193 - Mere because of Provision made in the books of account as per Accounting Standards, where no income has accrued to or has been received by then debenture holders, TDS not required to be deducted - Assessee cannot be treated in default - AT
Non deduction of tax at source in respect of interest on debenture u/s 193 - Mere because of Provision made in the books of account as per Accounting Standards, where no income has accrued to or has been received by then debenture holders, TDS not required to be deducted - Assessee cannot be treated in default - AT
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