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...
For the purposes of deduction of tax u/s 194LBB, or u/s 194LBC the “rates in force” in relation to an assessment year or financial year shall mean the rate or rates of income-tax specified in this behalf in the Finance Act of the relevant year or rate or rates of incometax specified in an agreement entered into by the Central Government u/s 90 or notified by the Central Government u/s 90A, whichever is applicable.
For the purposes of deduction of tax u/s 194LBB, or u/s 194LBC the “rates in force” in relation to an assessment year or financial year shall mean the rate or rates of income-tax specified in this behalf in the Finance Act of the relevant year or rate or rates of incometax specified in an agreement entered into by the Central Government u/s 90 or notified by the Central Government u/s 90A, whichever is applicable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
