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...
Additions towards amount of TDS deducted on interest - accrual of interest income but not received - Merely because the borrower has deposited TDS amount that itself will not fasten liability on the assessee to pay tax on the total interest income especially under the circumstances, when the other party has failed to repay the loan amount and interest thereupon and the litigation was going on. - AT
Additions towards amount of TDS deducted on interest - accrual of interest income but not received - Merely because the borrower has deposited TDS amount that itself will not fasten liability on the assessee to pay tax on the total interest income especially under the circumstances, when the other party has failed to repay the loan amount and interest thereupon and the litigation was going on. - AT
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