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 194H - Whether sale of recharge vouchers and prepaid vouchers and prepaid cards to the sole distributors does not establish Principal-Agent relationship liable to TDS under section 194H? - other High Court’s decisions are binding on the Tribunal to take a decision, but, since there exist two contradictory decisions other High Courts, if a statutory provision is capable of more than one view, then the view which favours the tax payer should be preferred.
TDS u/s 194H - Whether sale of recharge vouchers and prepaid vouchers and prepaid cards to the sole distributors does not establish Principal-Agent relationship liable to TDS under section 194H? - other High Court’s decisions are binding on the Tribunal to take a decision, but, since there exist two contradictory decisions other High Courts, if a statutory provision is capable of more than one view, then the view which favours the tax payer should be preferred.
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