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...
TCS on Scrap - section 206C - there is no requirement that the goods to be eligible for scrap should be produced/manufacture by the seller itself. - In present assessee’s case the assessee has not filed prescribed Form 27C thereby exempting the seller to collect tax under Section 206C - CIT(A) has rightly made tax liability including interest u/s 206C - AT
TCS on Scrap - section 206C - there is no requirement that the goods to be eligible for scrap should be produced/manufacture by the seller itself. - In present assessee’s case the assessee has not filed prescribed Form 27C thereby exempting the seller to collect tax under Section 206C - CIT(A) has rightly made tax liability including interest u/s 206C - AT
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