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 u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT
TDS u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT
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