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 liability u/s 195 - transfer of immovable property by the non-residents to resident - all the three non-residents have filed their return of income in India for the relevant assessment year declaring nil capital gains - AO has rightly held the as assessee in default for non deduction of tax at source u/s 201(1).
TDS liability u/s 195 - transfer of immovable property by the non-residents to resident - all the three non-residents have filed their return of income in India for the relevant assessment year declaring nil capital gains - AO has rightly held the as assessee in default for non deduction of tax at source u/s 201(1).
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