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...
Provision for repair of unserviceable spare parts in an airline business was treated as an allowable business expenditure rather than a mere contingent liability, because the Tribunal found the inventory and repair outgo to be part of the ordinary recurring business cycle and accepted estimation-based provisioning under Bharat Earth Movers and Chainrup Sampatram. The disallowance was deleted, subject to proper computation in accordance with law. The claim for provision for obsolescence of Bid & Win inventory was rejected for the year under appeal, as the Department stated it had been accepted in the succeeding assessment year. Other disallowance grounds were not pressed before the CIT(A).
Provision for repair of unserviceable spare parts in an airline business was treated as an allowable business expenditure rather than a mere contingent liability, because the Tribunal found the inventory and repair outgo to be part of the ordinary recurring business cycle and accepted estimation-based provisioning under Bharat Earth Movers and Chainrup Sampatram. The disallowance was deleted, subject to proper computation in accordance with law. The claim for provision for obsolescence of Bid & Win inventory was rejected for the year under appeal, as the Department stated it had been accepted in the succeeding assessment year. Other disallowance grounds were not pressed before the CIT(A).
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