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 OR 194J - document management charges - the work assigned to the service provider was not a technical or professional work which required special skills but simple, basic and repetitive nature of work and accordingly subject to tax u/s 194C.
TDS u/s 194C OR 194J - document management charges - the work assigned to the service provider was not a technical or professional work which required special skills but simple, basic and repetitive nature of work and accordingly subject to tax u/s 194C.
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