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 194 - Since this Tribunal has already taken a view that the person to whom interest was paid was falling within the ambit of section 194A(3)(f), there cannot be any order treating the assessee as an assessee in default u/s. 201(1) and also levying interest u/s. 201(1A)
TDS u/s 194 - Since this Tribunal has already taken a view that the person to whom interest was paid was falling within the ambit of section 194A(3)(f), there cannot be any order treating the assessee as an assessee in default u/s. 201(1) and also levying interest u/s. 201(1A)
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