Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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 194J - roaming charges paid by it to other service providers - the payments made for interconnection are not fees for rendering any technical services as envisaged in section 194J, therefore, no tax is de ductible at source u/s 194J on payment of roaming charges to the OTOs and the assessee therefore cannot be treated as an assessee in default
TDS u/s 194J - roaming charges paid by it to other service providers - the payments made for interconnection are not fees for rendering any technical services as envisaged in section 194J, therefore, no tax is de ductible at source u/s 194J on payment of roaming charges to the OTOs and the assessee therefore cannot be treated as an assessee in default
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