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...
Eligibility for deduction U/s.11 & 12 - The claim of the assessee to carry forward the excess application of fund cannot be entertained applying the commercial principles. However if the excess application of funds are from the borrowed fund or from the sundry creditors during the earlier years, the same shall be allowed as application in the year in which such loan or sundry creditors are repaid from the income of the trust. - AT
Eligibility for deduction U/s.11 & 12 - The claim of the assessee to carry forward the excess application of fund cannot be entertained applying the commercial principles. However if the excess application of funds are from the borrowed fund or from the sundry creditors during the earlier years, the same shall be allowed as application in the year in which such loan or sundry creditors are repaid from the income of the trust. - AT
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