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...
Deduction u/s 80IB - there is substantial force in the claim of the assessee that deduction u/s 80IB has to be allowed on the amount of profits and gains derived by him the eligible business within the meaning of the said statutory provision, as finally determined. - Disallowance of expenses claimed by the assessee as regards his eligible business would increase its income which again will be exempt u/s 80IB. - AT
Deduction u/s 80IB - there is substantial force in the claim of the assessee that deduction u/s 80IB has to be allowed on the amount of profits and gains derived by him the eligible business within the meaning of the said statutory provision, as finally determined. - Disallowance of expenses claimed by the assessee as regards his eligible business would increase its income which again will be exempt u/s 80IB. - AT
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