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 194I - Disallowance u/s. 40(a)(ia) - property owned by three persons jointly - in terms of Section 27, the owners did not constitute an AOP but they had to be regarded as co-owners of the house property - since the rent paid to each individual does not exceed ₹ 1,80,000/ annually - Section 194I not applicable
TDS u/s 194I - Disallowance u/s. 40(a)(ia) - property owned by three persons jointly - in terms of Section 27, the owners did not constitute an AOP but they had to be regarded as co-owners of the house property - since the rent paid to each individual does not exceed ₹ 1,80,000/ annually - Section 194I not applicable
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