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...
Levy of late fee u/s 234E - late filing of quarterly electronic TDS returns, as provided u/s 200(3) for AY 2013-14 - the levy of fees u/s 234E for any period prior to 01/06/2015 would not be sustainable in the eyes of law.
Levy of late fee u/s 234E - late filing of quarterly electronic TDS returns, as provided u/s 200(3) for AY 2013-14 - the levy of fees u/s 234E for any period prior to 01/06/2015 would not be sustainable in the eyes of law.
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