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...
Demand raised u/s 200A - demand raised by way of fee u/s 234E for belated filing of Statement of TDS - we condone the delay that occurred between the date of intimation u/s 200A and the date of downloading of “Default Summary”. Accordingly, the assessee should have filed appeal from 30 days of date of downloading of “Default Summary”.
Demand raised u/s 200A - demand raised by way of fee u/s 234E for belated filing of Statement of TDS - we condone the delay that occurred between the date of intimation u/s 200A and the date of downloading of “Default Summary”. Accordingly, the assessee should have filed appeal from 30 days of date of downloading of “Default Summary”.
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