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...
Failure to collect tax at source (TCS) u/s on the sales - whether the material is scrap or not - assessee failed to collect TCS @ 1% - Since taxes have already been paid by the buyers and there was no tax demand remained. - No penalty - AT
Failure to collect tax at source (TCS) u/s on the sales - whether the material is scrap or not - assessee failed to collect TCS @ 1% - Since taxes have already been paid by the buyers and there was no tax demand remained. - No penalty - AT
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