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...
Related-party advances by a charitable society did not warrant denial of exemption where the construction advance arose in ordinary construction activity and no evidence showed personal benefit to specified persons, overpricing, or non-arm's-length terms. Advances to registered charitable institutions were not shown to divert funds for private benefit. Section 40A(2)(a) could not apply because the disputed interest was paid to unrelated banks, making the related disallowance and notional-interest addition unsustainable. Donations to registered charitable entities undertaking charitable activities were permissible application of income, and scholarships were claimed as charitable application. The disallowances were deleted and exemption under sections 11 and 12 was extended.
Related-party advances by a charitable society did not warrant denial of exemption where the construction advance arose in ordinary construction activity and no evidence showed personal benefit to specified persons, overpricing, or non-arm's-length terms. Advances to registered charitable institutions were not shown to divert funds for private benefit. Section 40A(2)(a) could not apply because the disputed interest was paid to unrelated banks, making the related disallowance and notional-interest addition unsustainable. Donations to registered charitable entities undertaking charitable activities were permissible application of income, and scholarships were claimed as charitable application. The disallowances were deleted and exemption under sections 11 and 12 was extended.
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