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 195 - addition u/s.40(a)(i) - commission payable to the foreign agent - a person paying interest or any other sum to a non-resident is not liable to deduct tax if such sum is not chargeable to tax under the Act - neither TDS nor disallowance
TDS u/s 195 - addition u/s.40(a)(i) - commission payable to the foreign agent - a person paying interest or any other sum to a non-resident is not liable to deduct tax if such sum is not chargeable to tax under the Act - neither TDS nor disallowance
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