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 - non deduction of TDS - demurrage charges paid by the respondent-assessee to the foreign companies - The ITAT upheld the decision of the CIT(A) to delete the addition of demurrage charges, citing the precedent set by the Full Bench of the Bombay High Court.
TDS u/s 195 - non deduction of TDS - demurrage charges paid by the respondent-assessee to the foreign companies - The ITAT upheld the decision of the CIT(A) to delete the addition of demurrage charges, citing the precedent set by the Full Bench of the Bombay High Court.
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