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...
The ld. CIT(A) confirmed the addition of ₹ 1 lac on estimated basis when commission payments are specified amount, the CIT(A) should have confirmed the whole commission payment - Therefore, in absence of proper evidence with the assessee for claiming the expenditure as incurred wholly and exclusively for the business purposes, we confirm the addition of whole amount - AT
The ld. CIT(A) confirmed the addition of ₹ 1 lac on estimated basis when commission payments are specified amount, the CIT(A) should have confirmed the whole commission payment - Therefore, in absence of proper evidence with the assessee for claiming the expenditure as incurred wholly and exclusively for the business purposes, we confirm the addition of whole amount - AT
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