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...
Actuarial-deficit contributions to an approved superannuation fund are distinguished from ordinary annual and initial contributions by their purpose. Ad hoc payments required to align fund assets with actuarial liabilities and cure accumulated funding deficiencies fall outside the Rule 87 ceiling for ordinary annual contributions; applying that ceiling could undermine the fund's solvency and the deduction framework for approved funds. A reasoned appellate determination based on jurisdictional precedent is not perverse or arbitrary merely because the revenue disputes its application. The disallowance of actuarially determined deficit contributions was deleted, and the revenue's challenge failed.
Actuarial-deficit contributions to an approved superannuation fund are distinguished from ordinary annual and initial contributions by their purpose. Ad hoc payments required to align fund assets with actuarial liabilities and cure accumulated funding deficiencies fall outside the Rule 87 ceiling for ordinary annual contributions; applying that ceiling could undermine the fund's solvency and the deduction framework for approved funds. A reasoned appellate determination based on jurisdictional precedent is not perverse or arbitrary merely because the revenue disputes its application. The disallowance of actuarially determined deficit contributions was deleted, and the revenue's challenge failed.
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