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...
Disallowance u/s 40(a)(ia) - Non deduction of TDS u/s 194A - Interest - the provisions of section 194A have no application in case where no interest is credited to the account of the parties nor was paid during the previous year relevant to the assessment year under consideration. - Additions deleted - AT
Disallowance u/s 40(a)(ia) - Non deduction of TDS u/s 194A - Interest - the provisions of section 194A have no application in case where no interest is credited to the account of the parties nor was paid during the previous year relevant to the assessment year under consideration. - Additions deleted - AT
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