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 194A(3)(ix) - TDS on accrued interest on the compensation amount - compensation and interest thereupon awarded by Motor Accident Claims Tribunal, by no stretch of imagination, can be said to be ‘income’ rather same being ‘damages’ granted by court on account of injury or death in accidental cases, cannot be subjected to TDS u/s 194A - HC
TDS u/s 194A(3)(ix) - TDS on accrued interest on the compensation amount - compensation and interest thereupon awarded by Motor Accident Claims Tribunal, by no stretch of imagination, can be said to be ‘income’ rather same being ‘damages’ granted by court on account of injury or death in accidental cases, cannot be subjected to TDS u/s 194A - HC
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