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...
Addition u/s. 40(a)(ia) for failure of TDS u/s 194C - if the payees have reflected the payment in their respective Return of Income and has paid tax and fulfils the conditions stipulated u/s. 200, then no disallowance u/s. 40(a)(ia) is warranted.
Addition u/s. 40(a)(ia) for failure of TDS u/s 194C - if the payees have reflected the payment in their respective Return of Income and has paid tax and fulfils the conditions stipulated u/s. 200, then no disallowance u/s. 40(a)(ia) is warranted.
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