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...
Applicability of MAT section 115JB to the assessee being a Banking Company - there is not a single decision of the Jurisdictional High Court or even of any other Hon’ble High Court which is in favour of the Revenue on this issue - the provision of section 115JB was not applicable in the case of the assessee being a Banking company for the year under consideration, i.e. A.Y. 2010-11
Applicability of MAT section 115JB to the assessee being a Banking Company - there is not a single decision of the Jurisdictional High Court or even of any other Hon’ble High Court which is in favour of the Revenue on this issue - the provision of section 115JB was not applicable in the case of the assessee being a Banking company for the year under consideration, i.e. A.Y. 2010-11
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