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 194I OR 194C - failure to deduct tax correctly on hire charges - ‘Assessee in default’ - the assessee has failed to discharge its onus to prove by furnishing documents to show that vehicles were operated by the contractor - Action of revenue sustained.
TDS u/s 194I OR 194C - failure to deduct tax correctly on hire charges - ‘Assessee in default’ - the assessee has failed to discharge its onus to prove by furnishing documents to show that vehicles were operated by the contractor - Action of revenue sustained.
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