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...
DTAA – Since contract was for less than six months, it becomes absolutely clear that the assessee did not have a permanent establishment in India as per article 5(3) of the treaty - HC
DTAA – Since contract was for less than six months, it becomes absolutely clear that the assessee did not have a permanent establishment in India as per article 5(3) of the treaty - HC
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