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...
Addition u/s 40A(3) being 20% of the amount paid - assessee was acquiring the land from the various farmers by paying cash to them and debiting it to the capital work in progress account. This sum was not claimed as an “expenditure‟ in the profit and loss account. - The whole transaction of purchase of land as well as transfer to the sister concern was not routed through profit and loss account but were shown in the balance sheet. - No additions.
Addition u/s 40A(3) being 20% of the amount paid - assessee was acquiring the land from the various farmers by paying cash to them and debiting it to the capital work in progress account. This sum was not claimed as an “expenditure‟ in the profit and loss account. - The whole transaction of purchase of land as well as transfer to the sister concern was not routed through profit and loss account but were shown in the balance sheet. - No additions.
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