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 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT
Tds U/S 195 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT
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