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...
Refund of TDS to the deductor - CIT(A) allowed the refund - as per the CBDT’s Circular No.2/2011 dated 2.04.2011, there is a procedure for the deductor to claim refund before the AO. - the order of the CIT(A) cannot be sustained and the credit for TDS cannot be allowed to the assessee in facts and circumstances of the case - AT
Refund of TDS to the deductor - CIT(A) allowed the refund - as per the CBDT’s Circular No.2/2011 dated 2.04.2011, there is a procedure for the deductor to claim refund before the AO. - the order of the CIT(A) cannot be sustained and the credit for TDS cannot be allowed to the assessee in facts and circumstances of the case - AT
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