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...
Interest u/s 234B - scope of amendment in section 209 - entire payment received by the assessee from India was subject to TDS hence no interest is chargeable - The amendment brought into the act by the FA 2012 is applicable with effect from 01.04.2012 and is applicable from assessment year 2013 – 14 and prospective in nature
Interest u/s 234B - scope of amendment in section 209 - entire payment received by the assessee from India was subject to TDS hence no interest is chargeable - The amendment brought into the act by the FA 2012 is applicable with effect from 01.04.2012 and is applicable from assessment year 2013 – 14 and prospective in nature
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