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...
Additions for non-deduction of TDS - Sec 40(a)(ia) is a disabling provision which and not an enabling provision. - there is nothing in the language of Sec.40(a)(ia) to the effect that it is only when an Assessee is treated as an Assessee in default under Chapter XVII B of the Act by an order passed u/s.201(1) of the Act, can a disallowance be made u/s.40(a)(ia).
Additions for non-deduction of TDS - Sec 40(a)(ia) is a disabling provision which and not an enabling provision. - there is nothing in the language of Sec.40(a)(ia) to the effect that it is only when an Assessee is treated as an Assessee in default under Chapter XVII B of the Act by an order passed u/s.201(1) of the Act, can a disallowance be made u/s.40(a)(ia).
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