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...
Exemption u/s 11 - AO made the addition on the ground that since the five years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) - AO directed to verify, if AY 2013-14 is not the period within which the accumulated surplus has to be applied, then the addition made should be deleted. - AT
Exemption u/s 11 - AO made the addition on the ground that since the five years period expires in AY 2013-14, and since the assessee did not utilize the sum accumulated for charitable purpose in terms of section 11(3)(c) - AO directed to verify, if AY 2013-14 is not the period within which the accumulated surplus has to be applied, then the addition made should be deleted. - AT
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