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...
Registration under Section 12AA refused - Whatever may be the correctness or otherwise of the said findings of the learned CIT, it is only the amended objects that have to be considered for purpose of grant of Registration. Thus, in our view, the objections of the ld. CIT with regard to the provisions of section 13(1)(b) of the Act, are therefore no longer relevant. - AT
Registration under Section 12AA refused - Whatever may be the correctness or otherwise of the said findings of the learned CIT, it is only the amended objects that have to be considered for purpose of grant of Registration. Thus, in our view, the objections of the ld. CIT with regard to the provisions of section 13(1)(b) of the Act, are therefore no longer relevant. - AT
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