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 80-IAB extends to interest earned on unutilised business funds compulsorily placed in fixed deposits, including deposits made at the insistence of financial institutions, where the interest is treated as business income rather than income from other sources. Expenditure disallowance under section 14A read with rule 8D cannot exceed the exempt income earned. Accordingly, the deduction for qualifying fixed-deposit interest was upheld, and the disallowance relating to exempt income was restricted to the amount of exempt income.
Deduction under section 80-IAB extends to interest earned on unutilised business funds compulsorily placed in fixed deposits, including deposits made at the insistence of financial institutions, where the interest is treated as business income rather than income from other sources. Expenditure disallowance under section 14A read with rule 8D cannot exceed the exempt income earned. Accordingly, the deduction for qualifying fixed-deposit interest was upheld, and the disallowance relating to exempt income was restricted to the amount of exempt income.
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