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 194J OR 194C - treating annual maintenance contracts “AMC” payments made to various payees as fee for technical services - the amount paid cannot be considered as fees for technical services within the meaning of section 194J.
TDS u/s 194J OR 194C - treating annual maintenance contracts “AMC” payments made to various payees as fee for technical services - the amount paid cannot be considered as fees for technical services within the meaning of section 194J.
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