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 u/s 194I OR 194C - External Development Charges (‘EDC’) paid to Haryana Urban Development Authority (‘HUDA’) - the Revenue does not seek to support the decision of the AO that EDC are ‘rent’ or in the nature of ‘rent’. Thus, concededly, the fundamental reasoning on which the impugned order rests is fundamentally flawed. - Petitioners in these petitions were required to deduct TDS from EDC under Section 194-I - HC
TDS u/s 194I OR 194C - External Development Charges (‘EDC’) paid to Haryana Urban Development Authority (‘HUDA’) - the Revenue does not seek to support the decision of the AO that EDC are ‘rent’ or in the nature of ‘rent’. Thus, concededly, the fundamental reasoning on which the impugned order rests is fundamentally flawed. - Petitioners in these petitions were required to deduct TDS from EDC under Section 194-I - HC
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