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...
Deduction under section 36(1)(vii) was held to operate distinctly from provision-based deduction under section 36(1)(viia), and the proviso was applied only to prevent double deduction; on the facts already accepted in earlier years, no duplication was shown, so the disallowance of bad debts written off was deleted. The Tribunal also held that earlier coordinate bench rulings remained binding despite pending High Court appeals in the absence of any stay or reversal, and the Revenue's challenge failed. On the amortised lease premium issue, the Tribunal applied section 158A because an identical question of law was already pending before the High Court, and directed that the final High Court decision be applied to the years in appeal.
Deduction under section 36(1)(vii) was held to operate distinctly from provision-based deduction under section 36(1)(viia), and the proviso was applied only to prevent double deduction; on the facts already accepted in earlier years, no duplication was shown, so the disallowance of bad debts written off was deleted. The Tribunal also held that earlier coordinate bench rulings remained binding despite pending High Court appeals in the absence of any stay or reversal, and the Revenue's challenge failed. On the amortised lease premium issue, the Tribunal applied section 158A because an identical question of law was already pending before the High Court, and directed that the final High Court decision be applied to the years in appeal.
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