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 - disallowance u/s 40(a)(ia) - freight received and freight paid difference is only 1.15% - assessee actually engaged not in the transportation business,but only facilitating or arranging transportation for various parties and he is a mere lorry booking agent - cannot be held as the “person responsible” for deduction of TDS - no disallowance
TDS u/s 194C - disallowance u/s 40(a)(ia) - freight received and freight paid difference is only 1.15% - assessee actually engaged not in the transportation business,but only facilitating or arranging transportation for various parties and he is a mere lorry booking agent - cannot be held as the “person responsible” for deduction of TDS - no disallowance
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