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...
Disallowance u/s 40(a)(ia) - commission paid to foreign agents from India - All services are rendered abroad - When the payment made by the assessee to the overseas agent is not income chargeable to tax in India then there was no obligation on assessee to deduct TDS u/s 195 - disallowance u/s 40(a)(ia) not attracted
Disallowance u/s 40(a)(ia) - commission paid to foreign agents from India - All services are rendered abroad - When the payment made by the assessee to the overseas agent is not income chargeable to tax in India then there was no obligation on assessee to deduct TDS u/s 195 - disallowance u/s 40(a)(ia) not attracted
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