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 - reimbursement of postage expense on actual basis - there is no case for invoking the provisions u/s 194C which only mandates for effecting TDS as per the contract norm - AT
TDS u/s 194C - reimbursement of postage expense on actual basis - there is no case for invoking the provisions u/s 194C which only mandates for effecting TDS as per the contract norm - AT
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