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...
Non-payment of tax for Assessment Years 2005-06 and 2006-07 - Liability to pay interest u/s 234B. Prior to the insertion of proviso to Section 209(1), if the payer defaulted in deducting tax at source from payments to non-residents, the non-resident was not absolved from paying taxes, and the question of advance tax payment did not arise. The Supreme Court disposed of the appeal due to low tax effect, keeping any question of law open. Pending applications were also disposed of.
Non-payment of tax for Assessment Years 2005-06 and 2006-07 - Liability to pay interest u/s 234B. Prior to the insertion of proviso to Section 209(1), if the payer defaulted in deducting tax at source from payments to non-residents, the non-resident was not absolved from paying taxes, and the question of advance tax payment did not arise. The Supreme Court disposed of the appeal due to low tax effect, keeping any question of law open. Pending applications were also disposed of.
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