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 – payment of interest is made to a Corporation established by a State Act – notified institution u/s 194A(3)(iii)(f) - Sec. 194A(1) not applicable - AT
TDS – payment of interest is made to a Corporation established by a State Act – notified institution u/s 194A(3)(iii)(f) - Sec. 194A(1) not applicable - AT
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