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 - advancing a loan to another charitable trust - nothing has been brought on record to establish that the common trustees have substantial interest in the other trust - the amount advanced cannot be held to be in violation of Sec.13(1)(d) - Sec.11(5) cannot be applied to present facts as the money advanced is not an investment but a loan - Exemption cannot be denied - AT
Exemption u/s 11 - advancing a loan to another charitable trust - nothing has been brought on record to establish that the common trustees have substantial interest in the other trust - the amount advanced cannot be held to be in violation of Sec.13(1)(d) - Sec.11(5) cannot be applied to present facts as the money advanced is not an investment but a loan - Exemption cannot be denied - AT
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