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...
Where assessee is non-resident company, entire tax to be deducted at source at payments made by the payers to it and there was no question nof payment of advance tax by the assessee, therefore, revenue could not charge any interest u/s 234B. - AT
Where assessee is non-resident company, entire tax to be deducted at source at payments made by the payers to it and there was no question nof payment of advance tax by the assessee, therefore, revenue could not charge any interest u/s 234B. - AT
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