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...
The Tribunal restricted disallowance for a political donation deduction to the amount actually shown in the assessee's bank records, holding that a higher figure had no factual basis. It also sustained deletion of the section 69A addition for a bank time deposit, accepting that the deposit was made from disclosed salary income and that the Revenue produced no rebuttal. In respect of gratuity, leave encashment and employee allowance receipts reflected in Form 16, the Tribunal upheld the relief granted because the appellate findings were clear and remained unchallenged. The Revenue's appeal was dismissed.
The Tribunal restricted disallowance for a political donation deduction to the amount actually shown in the assessee's bank records, holding that a higher figure had no factual basis. It also sustained deletion of the section 69A addition for a bank time deposit, accepting that the deposit was made from disclosed salary income and that the Revenue produced no rebuttal. In respect of gratuity, leave encashment and employee allowance receipts reflected in Form 16, the Tribunal upheld the relief granted because the appellate findings were clear and remained unchallenged. The Revenue's appeal was dismissed.
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