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...
Unabsorbed investment allowance - allowance u/s 32A (6) - AO had to see whether the assessee had fulfilled the conditions of section 32A(6) but he laid emphasis on the provisions of section 72A of the Act, which is misplaced. - The appellant has elaborately shown that the conditions specified in section 32A(6) of the Act are fulfilled by it. Therefore, the claim of the appellant is fully justified.
Unabsorbed investment allowance - allowance u/s 32A (6) - AO had to see whether the assessee had fulfilled the conditions of section 32A(6) but he laid emphasis on the provisions of section 72A of the Act, which is misplaced. - The appellant has elaborately shown that the conditions specified in section 32A(6) of the Act are fulfilled by it. Therefore, the claim of the appellant is fully justified.
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