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 194I - Levy of interest u/s 201(1A) - lease rent paid to Noida authority - If the said interest has already been paid by the NOIDA, no recovery can be made from the assessee for the said amount of the interest. - Assessee directed to cooperate and provide the relevant information required by the AO - AT
TDS u/s 194I - Levy of interest u/s 201(1A) - lease rent paid to Noida authority - If the said interest has already been paid by the NOIDA, no recovery can be made from the assessee for the said amount of the interest. - Assessee directed to cooperate and provide the relevant information required by the AO - AT
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