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...
Constitutional validity and legality of Section 194N - Deduction of tax at source at the rate of 2% on cash withdrawals from, inter alia, a banking company exceeding ₹ 1 crore in a financial year - Considering the facts, we are inclined to grant an interim order restraining the respondents authorities concerned from deducting tax on source on the basis of the aforesaid provisions of Section 194N till 30th September, 2021. - HC
Constitutional validity and legality of Section 194N - Deduction of tax at source at the rate of 2% on cash withdrawals from, inter alia, a banking company exceeding ₹ 1 crore in a financial year - Considering the facts, we are inclined to grant an interim order restraining the respondents authorities concerned from deducting tax on source on the basis of the aforesaid provisions of Section 194N till 30th September, 2021. - HC
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