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...
Set off and withholding of refunds in certain cases - It has been proposed to amend section 245 & 241A by integrating to set off refunds against tax remaining payable. Also, where proceedings of assessment or reassessment are pending additional interest shall not be payable on amount of refund withheld for that purpose during assessment proceeding periods.
Set off and withholding of refunds in certain cases - It has been proposed to amend section 245 & 241A by integrating to set off refunds against tax remaining payable. Also, where proceedings of assessment or reassessment are pending additional interest shall not be payable on amount of refund withheld for that purpose during assessment proceeding periods.
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