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 195 on payment of secondment cost - The assessee has reimbursed the salary cost of seconded employees on cost-to-cost basis without any profit element. The assessee has duly deducted tax at source from these payments u/s 192 - The stated employees have worked under the supervision and control of the assessee. - No further requirement of deduction of TDS u/s 195 - AT
TDS u/s 195 on payment of secondment cost - The assessee has reimbursed the salary cost of seconded employees on cost-to-cost basis without any profit element. The assessee has duly deducted tax at source from these payments u/s 192 - The stated employees have worked under the supervision and control of the assessee. - No further requirement of deduction of TDS u/s 195 - AT
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