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 on account of deemed dividend u/s 2(22)(e) - Admittedly, the assessee company is registered with stock exchange and fulfill all the conditions of Section 2(18) which is definition of “company in which public is substantially interested.” - AO has also failed to substantiate as to how the amount in question is in the shape of a loan/advance received by the assessee company. - Additions deleted - AT
Addition on account of deemed dividend u/s 2(22)(e) - Admittedly, the assessee company is registered with stock exchange and fulfill all the conditions of Section 2(18) which is definition of “company in which public is substantially interested.” - AO has also failed to substantiate as to how the amount in question is in the shape of a loan/advance received by the assessee company. - Additions deleted - AT
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