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...
Addition for no TDS on Deemed dividend u/s 2(22)(e) - whether the amounts given the directors are for the business purpose? - the ledger account of the said directors does not reflect any transactions or details where from it can be perceived that the transactions are in the nature of normal business transactions, much less the said transactions were not substantiated with any documentary evidence substantiating that these pertains to or have any nexus with the business of the assessee company - However, no additions can be made u/s 40(a)(ia) on deemed dividend for no TDS - AT
Addition for no TDS on Deemed dividend u/s 2(22)(e) - whether the amounts given the directors are for the business purpose? - the ledger account of the said directors does not reflect any transactions or details where from it can be perceived that the transactions are in the nature of normal business transactions, much less the said transactions were not substantiated with any documentary evidence substantiating that these pertains to or have any nexus with the business of the assessee company - However, no additions can be made u/s 40(a)(ia) on deemed dividend for no TDS - AT
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