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...
Employee on deputation - computation of total salary paid as provided in Section 195A - income tax liability on the salary received by the appellant from the consultant company - AO directed to employ Section 195A
Employee on deputation - computation of total salary paid as provided in Section 195A - income tax liability on the salary received by the appellant from the consultant company - AO directed to employ Section 195A
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