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...
Requirement of application of non deduction of TDS u/s 195(2) - unless person (deductor) is responsible for paying any sum chargeable under the Act - there is no question of making any application u/s 195(2)
Requirement of application of non deduction of TDS u/s 195(2) - unless person (deductor) is responsible for paying any sum chargeable under the Act - there is no question of making any application u/s 195(2)
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