Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
TDS u/s 194C - determination of job work charges / miller cost - milling of paddy - As per AO milling costs paid by the appellant are discounted costs and need to be increased by the cost of by-products for the purpose of TDS - since we have held that the property in the by-product was not passed on by the assessee / Procurement Agencies as milling charges, hence, it is held that TDS provisions of section 194C are not attracted in this case. - AT
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