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 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
Disallowance u/s 40(a)(ia) - payment of pigmy commission had direct nexus with the business income of the assessee on which deduction u/s 80P(2)(a)(i) was claimed - If the disallowance u/s.40(a)(i) results in increase in income which would otherwise go to enhance the income on which the Assessee is eligible for deduction, then the CBDT Circular would be applicable and deduction will be allowable
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