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 194C - addition u/s 40(a)(ia) - purchase from various manufacturers who in turn manufacture the same as per the specifications provided by the assessee - not in the nature of works contract but it is agreements for purchase of goods simpliciter.
TDS u/s 194C - addition u/s 40(a)(ia) - purchase from various manufacturers who in turn manufacture the same as per the specifications provided by the assessee - not in the nature of works contract but it is agreements for purchase of goods simpliciter.
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