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...
In banking-tax matters, intra-entity interest received by an Indian branch from its head office and overseas branches was treated as internal allocation, not real income, because the deeming rule for interest could not be stretched to a transaction with oneself; the addition was deleted. Centralised hub service charges for data processing, monitoring and risk support were held to be direct operational costs, not restricted head office overheads, and the disallowance was deleted. Broken period interest, mark-to-market loss on unmatured forward contracts, and diminution in value of securities held as stock-in-trade were each allowed as revenue deductions. Reimbursement of expatriate salary was also upheld as branch-specific cost, while the exempt-income disallowance ground was dismissed.
In banking-tax matters, intra-entity interest received by an Indian branch from its head office and overseas branches was treated as internal allocation, not real income, because the deeming rule for interest could not be stretched to a transaction with oneself; the addition was deleted. Centralised hub service charges for data processing, monitoring and risk support were held to be direct operational costs, not restricted head office overheads, and the disallowance was deleted. Broken period interest, mark-to-market loss on unmatured forward contracts, and diminution in value of securities held as stock-in-trade were each allowed as revenue deductions. Reimbursement of expatriate salary was also upheld as branch-specific cost, while the exempt-income disallowance ground was dismissed.
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