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...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
TDS (withholding tax) u/s 195 - Disallowance u/s 40(a)(i) - non-deduction of tax at source on payment made towards membership/subscription fee - principle of mutuality- amount paid by a member firm to the umbrella association - the payment made by the assessee to GTIL towards membership and subscription fee is not taxable at the hands of the payee. - No TDS liability - AT
TDS (withholding tax) u/s 195 - Disallowance u/s 40(a)(i) - non-deduction of tax at source on payment made towards membership/subscription fee - principle of mutuality- amount paid by a member firm to the umbrella association - the payment made by the assessee to GTIL towards membership and subscription fee is not taxable at the hands of the payee. - No TDS liability - AT
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