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. 194H / 192 - incentives paid to the employees - TDS liability - The total payment including salaries are below the threshold limits - Observation of the AO that assessee has changed the nomenclature of the expenses to incentives is not correct.
TDS u/s. 194H / 192 - incentives paid to the employees - TDS liability - The total payment including salaries are below the threshold limits - Observation of the AO that assessee has changed the nomenclature of the expenses to incentives is not correct.
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