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...
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
Ad hoc restriction of employee benefit expenditure requires reconciliation of salary details, vouchers, service evidence and business nexus, rather than comparison with revenue alone. Share premium additions turn on substantiation of fair market value under the valuation framework, and an incorrect statutory label does not displace the substance of the addition where no valuation report is produced. ESOP discount is recognised as employee compensation and potentially allowable as business expenditure, but the claim must be supported by valuation and grant-wise working. Loss on sale of subsidiary investment may be treated as business loss only where commercial expediency is established, and additional evidence must comply with Rule 46A and natural justice.
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