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 on late payment of TDS u/s 201(1A) - computation of period as "per month or part of the month" - British calendar months or otherwise - identical language in section 244A(1) as in section 201(1A) - For the purpose of computation of interest, the expression month is to be interpreted as period of 30 days and not British calendar.
Interest on late payment of TDS u/s 201(1A) - computation of period as "per month or part of the month" - British calendar months or otherwise - identical language in section 244A(1) as in section 201(1A) - For the purpose of computation of interest, the expression month is to be interpreted as period of 30 days and not British calendar.
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