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...
Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld
Disallowance u/s. 14A - recording of satisfaction - AO before invoking Rule 8D has issued SCN to the assessee. The AO after considering the reply of assessee negated the same giving reasons and thereafter made disallowance under Rule 8D. AO has recorded his satisfaction as envisaged u/s. 14A(3)- disallowance upheld
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