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 - TDS on overseas payment - Annual Payment made to the international boards through affiliation with IBO, Cambridge etc. under the head authorization fee, fee for enrolment, license fee, registration fee - assessee in default u/s 201/201(1A) - ITAT observed that the assessee failed to provide a basis for lump sum payments made to overseas institutions. Emphasized the importance of analyzing the basis of invoices raised by overseas institutions. Matter was remanded back to the Assessing Officer to understand the basis of lump sum fees and discounts offered to the assessee.
TDS u/s 195 - TDS on overseas payment - Annual Payment made to the international boards through affiliation with IBO, Cambridge etc. under the head authorization fee, fee for enrolment, license fee, registration fee - assessee in default u/s 201/201(1A) - ITAT observed that the assessee failed to provide a basis for lump sum payments made to overseas institutions. Emphasized the importance of analyzing the basis of invoices raised by overseas institutions. Matter was remanded back to the Assessing Officer to understand the basis of lump sum fees and discounts offered to the assessee.
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