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...
Section 194-IA applies transferee-wise, so the threshold for TDS on purchase of immovable property must be examined with reference to each joint transferee's share of consideration. Where an assessee's individual share is below the statutory limit, tax deduction cannot be insisted on merely because the total consideration under a single sale deed exceeds that limit. The order treating the assessee as in default under section 200A, and the appellate order sustaining it, were therefore unsustainable and the demand was set aside.
Section 194-IA applies transferee-wise, so the threshold for TDS on purchase of immovable property must be examined with reference to each joint transferee's share of consideration. Where an assessee's individual share is below the statutory limit, tax deduction cannot be insisted on merely because the total consideration under a single sale deed exceeds that limit. The order treating the assessee as in default under section 200A, and the appellate order sustaining it, were therefore unsustainable and the demand was set aside.
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