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 - short deduction of TDS - placement fees / carriage fees paid to cable operators - the activities covered by Section 194C are more specific and the activities covered by Section 194J are more general in terms - TDS liability confirmed u/s 194C
TDS u/s 194C OR 194J - short deduction of TDS - placement fees / carriage fees paid to cable operators - the activities covered by Section 194C are more specific and the activities covered by Section 194J are more general in terms - TDS liability confirmed u/s 194C
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