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 194H - assessee is a cellular mobile service providers - Aligning with the Supreme Court's judgment, the Gujarat High Court ruled in favor of the appellant, stating that the discounts given to distributors are not commissions and that the relationship between the parties is of principal to principal. Consequently, the appellant is not required to deduct tax at source under Section 194H of the Income Tax Act concerning the discounts offered to distributors.
TDS u/s 194H - assessee is a cellular mobile service providers - Aligning with the Supreme Court's judgment, the Gujarat High Court ruled in favor of the appellant, stating that the discounts given to distributors are not commissions and that the relationship between the parties is of principal to principal. Consequently, the appellant is not required to deduct tax at source under Section 194H of the Income Tax Act concerning the discounts offered to distributors.
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