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 192 - TDS - Salary - reimbursement/ payments made to employees under the head of uniform allowance - Whether the employee is able to substantiate his claim to exemption has no bearing on the estimate of income liable to tax to be made by the employer - self certification on the part of the employees was adequate for the assessee not to deduct tax from the reimbursement allowance towards expenditure incurred for uniforms. - HC
TDS u/s 192 - TDS - Salary - reimbursement/ payments made to employees under the head of uniform allowance - Whether the employee is able to substantiate his claim to exemption has no bearing on the estimate of income liable to tax to be made by the employer - self certification on the part of the employees was adequate for the assessee not to deduct tax from the reimbursement allowance towards expenditure incurred for uniforms. - HC
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