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 194C or 194I - Short-deduction of taxes - payments towards maintenance charges - Addition u/s 201(1) / 201(1 A) - assessee-in-default’ - the common area maintenance charges was not forming part of the actual rent paid to the owner by the assessee company. - Payments of rent and common area maintenance charges have been made to distinct entities/companies - AT
TDS u/s 194C or 194I - Short-deduction of taxes - payments towards maintenance charges - Addition u/s 201(1) / 201(1 A) - assessee-in-default’ - the common area maintenance charges was not forming part of the actual rent paid to the owner by the assessee company. - Payments of rent and common area maintenance charges have been made to distinct entities/companies - AT
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