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...
Exemption u/s 11 - Rejection of Application to grant registration of Trust u/s 12AA - So far as question of apprehensions raised by ld. CIT that under the garb of charitable activities, the Trustee are indulging into money laundering is concerned, this question can be taken care of by the appropriate forum as the person who is donating huge cash must be an incometax assessee, if not he or she can be brought to tax by the tax authorities - registration granted. - AT
Exemption u/s 11 - Rejection of Application to grant registration of Trust u/s 12AA - So far as question of apprehensions raised by ld. CIT that under the garb of charitable activities, the Trustee are indulging into money laundering is concerned, this question can be taken care of by the appropriate forum as the person who is donating huge cash must be an incometax assessee, if not he or she can be brought to tax by the tax authorities - registration granted. - AT
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