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) - cash payments were effected by the assessee for the purpose of acquiring rights to screen movies in their theatres as exceeded ₹ 20,000/- - Revenue is right in contending that the genuinity of the transaction is hardly a matter, which should weigh in the minds of the Assessing officer while examining as to the whether the assessees had violated Section 40A(3) - Additions confirmed - HC
Addition u/s.40A(3) - cash payments were effected by the assessee for the purpose of acquiring rights to screen movies in their theatres as exceeded ₹ 20,000/- - Revenue is right in contending that the genuinity of the transaction is hardly a matter, which should weigh in the minds of the Assessing officer while examining as to the whether the assessees had violated Section 40A(3) - Additions confirmed - HC
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