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 194C - payments of purchase to various vendors - Non deduction of TDS - Upon analysis, the Appellate Tribunal agreed with the assessee, ruling that the transactions were indeed purchases of finished goods. It noted that the manufacturers independently sourced raw materials and produced goods according to the specifications provided. Furthermore, the Tribunal found that the assessee's control over production was limited, as evidenced by the return of rejected goods to the vendors. Tribunal dismissed the revenue's appeal.
TDS u/s 194C - payments of purchase to various vendors - Non deduction of TDS - Upon analysis, the Appellate Tribunal agreed with the assessee, ruling that the transactions were indeed purchases of finished goods. It noted that the manufacturers independently sourced raw materials and produced goods according to the specifications provided. Furthermore, the Tribunal found that the assessee's control over production was limited, as evidenced by the return of rejected goods to the vendors. Tribunal dismissed the revenue's appeal.
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