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...
Short deduction of TDS - Non residents not having PAN - TDS @10% or 20% - invoking the provisions of Section 206AA - the PANs now made available for both the assessment years, the deductees are mostly from USA, China, Korea, Finland and Italy. DTAAs are available with all these five countries - the provisions of DTAA prevail over the provisions of I.T. Act, 1961 - AT
Short deduction of TDS - Non residents not having PAN - TDS @10% or 20% - invoking the provisions of Section 206AA - the PANs now made available for both the assessment years, the deductees are mostly from USA, China, Korea, Finland and Italy. DTAAs are available with all these five countries - the provisions of DTAA prevail over the provisions of I.T. Act, 1961 - AT
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