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 - payment was made without deducting TDS u/s 194 - Later on TDS amount debited to running account of payee - amount of TDS deposited before filing of return u/s 139 - Amount disallowed u/s 40(a)(ia) - AT
TDS - payment was made without deducting TDS u/s 194 - Later on TDS amount debited to running account of payee - amount of TDS deposited before filing of return u/s 139 - Amount disallowed u/s 40(a)(ia) - AT
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