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 195 - availing transponder facility - CIT (A) cannot hold that same payment would fall in the nature of ‘royalty’ and at same time would be reckoned as ‘FTS’ also. - AT
TDS u/s 195 - availing transponder facility - CIT (A) cannot hold that same payment would fall in the nature of ‘royalty’ and at same time would be reckoned as ‘FTS’ also. - AT
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