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 194A - interest paid to consumers on security deposit - Disallowance u/s. 40(a)(ia) ignoring the fact that average interest is merely Rs. 84/- per consumer and there will be large number of cases where interest amount paid on the security deposit may have been much below the prescribed limit for non-deduction of tax at source. - AT
TDS u/s 194A - interest paid to consumers on security deposit - Disallowance u/s. 40(a)(ia) ignoring the fact that average interest is merely Rs. 84/- per consumer and there will be large number of cases where interest amount paid on the security deposit may have been much below the prescribed limit for non-deduction of tax at source. - AT
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