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...
Expenses on account of construction - Charitable Trust - the assessee started the construction activity in earlier years i.e. A.Ys. 2010-11, 2011-12, 2012-13 & 2014-15 all the years the AO has allowed the expenditure incurred by the assessee. The only year under consideration, AO without giving proper opportunity has disallowed the expenditure incurred by the assessee is not correct. - CIT(A) rightly allowed the deduction.
Expenses on account of construction - Charitable Trust - the assessee started the construction activity in earlier years i.e. A.Ys. 2010-11, 2011-12, 2012-13 & 2014-15 all the years the AO has allowed the expenditure incurred by the assessee. The only year under consideration, AO without giving proper opportunity has disallowed the expenditure incurred by the assessee is not correct. - CIT(A) rightly allowed the deduction.
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