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 at lower rate u/s 197 - effective date of certificate - withholding tax certificate issued to the petitioner has been made effective from the date of issue OR from the beginning of the financial year i.e. 01.04.2019 - interim relief granted.
TDS at lower rate u/s 197 - effective date of certificate - withholding tax certificate issued to the petitioner has been made effective from the date of issue OR from the beginning of the financial year i.e. 01.04.2019 - interim relief granted.
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