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 194I - non deduction of TDS - compensation paid for the use of the building / premises / place of the members for construction activities - it would be highly unjustified to treat this amount as payment of rent and to make it liable for deduction of tax at source u/s 194-I. - invoking of provisions of section 40(a)(ia) is unjustified - AT
TDS u/s 194I - non deduction of TDS - compensation paid for the use of the building / premises / place of the members for construction activities - it would be highly unjustified to treat this amount as payment of rent and to make it liable for deduction of tax at source u/s 194-I. - invoking of provisions of section 40(a)(ia) is unjustified - AT
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