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...
Approval u/s. 80G(5) - entitlement to benefit of exemption u/s. 11 - fulfillment of terms of section 80G(5C)(iv) by depositing 1 crore of rupees in Prime Minister's National Relief Fund - assessee having made the credit entry in favour of educational institution had not retained any control over the monies and thus funds were made available to the institution by the Trust. Assessee could claim benefit of exemption u/s. 11 of the Act.
Approval u/s. 80G(5) - entitlement to benefit of exemption u/s. 11 - fulfillment of terms of section 80G(5C)(iv) by depositing 1 crore of rupees in Prime Minister's National Relief Fund - assessee having made the credit entry in favour of educational institution had not retained any control over the monies and thus funds were made available to the institution by the Trust. Assessee could claim benefit of exemption u/s. 11 of the Act.
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