Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
Enhancement u/s 92CA - “MAP” margin - the Revenue fails to dispute that even the Transfer Pricing Officer has not drawn any distinction qua the “ALP” in all the substantive grounds raised herein. We thus hold that the “MAP” margin of 15.49%, 15.34% and 15.76% deserves to be applied qua the remaining portion of non-USA based international transactions as well. - AT
Enhancement u/s 92CA - “MAP” margin - the Revenue fails to dispute that even the Transfer Pricing Officer has not drawn any distinction qua the “ALP” in all the substantive grounds raised herein. We thus hold that the “MAP” margin of 15.49%, 15.34% and 15.76% deserves to be applied qua the remaining portion of non-USA based international transactions as well. - AT
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