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 194J and u/s 195 - payment by way of reimbursement to member companies, allowances paid to resident and non-resident personnel and payment to foreign agents - reimbursement of Indian Salary and benefits - Member employer company deducts tax at source under section 192 of the Act from the Indian salary of such employee as they continue to get their salary from his employer member companies. - CIT(A) rightly held that assessee not in default u/s 201(1) - AT
TDS - u/s 194J and u/s 195 - payment by way of reimbursement to member companies, allowances paid to resident and non-resident personnel and payment to foreign agents - reimbursement of Indian Salary and benefits - Member employer company deducts tax at source under section 192 of the Act from the Indian salary of such employee as they continue to get their salary from his employer member companies. - CIT(A) rightly held that assessee not in default u/s 201(1) - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
