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 denied - intimation was issued u/s. 143(1) - The Central Processing Center has also taxed the entire gross receipt of the assessee without allowing any expenditure. This cannot be done while processing the return u/s. 143(1) of the Act. This Tribunal is of the considered opinion that Section 143(1) is meant for prima facie adjustment on the basis of material available on record without giving any opportunity to the assessee. Therefore, rejection of the claim of exemption u/s. 143(1) by Central Processing Center is not justified. - AT
Exemption u/s 11 denied - intimation was issued u/s. 143(1) - The Central Processing Center has also taxed the entire gross receipt of the assessee without allowing any expenditure. This cannot be done while processing the return u/s. 143(1) of the Act. This Tribunal is of the considered opinion that Section 143(1) is meant for prima facie adjustment on the basis of material available on record without giving any opportunity to the assessee. Therefore, rejection of the claim of exemption u/s. 143(1) by Central Processing Center is not justified. - AT
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