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...
Deduction u/s. 10B - Even though an estimation of excess stock in the middle of the year, while accepting the Books of Accounts of the year, is not generally permitted by various decisions of the ITAT, since Assessee is eligible for deduction u/s. 10B on the additions/disallowance made on these units, we are of the opinion that the same amount can be allowed for deduction u/s. 10B as the stock pertains to Hosur and Ongole units, which are eligible for deduction u/s. 10B. - AT
Deduction u/s. 10B - Even though an estimation of excess stock in the middle of the year, while accepting the Books of Accounts of the year, is not generally permitted by various decisions of the ITAT, since Assessee is eligible for deduction u/s. 10B on the additions/disallowance made on these units, we are of the opinion that the same amount can be allowed for deduction u/s. 10B as the stock pertains to Hosur and Ongole units, which are eligible for deduction u/s. 10B. - AT
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