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 u/s 194H - non-cash payment to dealers - impugned proceedings were beyond prescribed time limitation and thus the same deserve to be annulled. - AT
Non-deduction of tax at source u/s 194H - non-cash payment to dealers - impugned proceedings were beyond prescribed time limitation and thus the same deserve to be annulled. - AT
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