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...
Denial of TDS credit - non-deposit by employer - the Revenue in terms of Section 205 of the Act, is restrained from enforcing any tax recovery against the assessee insofar as the demand with reference to the amount of tax which had been deducted by the employer from the salary accrued to assessee and assuming that the deductor-employer had not remitted the amount after its deduction to the Central Government, the only course open to the Revenue is to recover same from the very person who has deducted the TDS and not from appellant assessee. - AT
Denial of TDS credit - non-deposit by employer - the Revenue in terms of Section 205 of the Act, is restrained from enforcing any tax recovery against the assessee insofar as the demand with reference to the amount of tax which had been deducted by the employer from the salary accrued to assessee and assuming that the deductor-employer had not remitted the amount after its deduction to the Central Government, the only course open to the Revenue is to recover same from the very person who has deducted the TDS and not from appellant assessee. - AT
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