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 - Tax deduction at source on the passengers’ services fees (PSF) - payment to CISF for security - assessee does not pay any sum to CISF but it is paid by the owners and operators of the airport - assessee cannot take shelter u/s 196 as the assessee is not payee to CISF but airport operators pay it - TDS liability confirmed.
TDS u/s 194J - Tax deduction at source on the passengers’ services fees (PSF) - payment to CISF for security - assessee does not pay any sum to CISF but it is paid by the owners and operators of the airport - assessee cannot take shelter u/s 196 as the assessee is not payee to CISF but airport operators pay it - TDS liability confirmed.
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