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...
Penalty u/s 271C - non deduction of tds u/s 194J / 194C by assessee charitable organization on time - the penalty u/s 271C of the Act cannot be levied for the delayed deduction of TDS amount. - AT
Penalty u/s 271C - non deduction of tds u/s 194J / 194C by assessee charitable organization on time - the penalty u/s 271C of the Act cannot be levied for the delayed deduction of TDS amount. - AT
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