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...
Addition u/s 40(a)(i) - TDS liability - bandwidth allocation by overseas service provider - fee for technical services - AO directed to examine the materials before him and call for additional expert or technical advice, as is necessary - HC
Addition u/s 40(a)(i) - TDS liability - bandwidth allocation by overseas service provider - fee for technical services - AO directed to examine the materials before him and call for additional expert or technical advice, as is necessary - HC
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