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 - Registration u/s 12AA - imparting education - the assessee was having necessary approval /affiliation from the respective authorities as required by the Commissioner exemption. These permission/ approval now produced by the necessary may not be necessary for the purposes of considering registration, as the same had already been filled with Board at the time of affilliation. Nonetheless now these permission / approval are available, there is no point of denying the registration on the pretext of alleged deficiency. - AT
Exemption u/s 11 - Registration u/s 12AA - imparting education - the assessee was having necessary approval /affiliation from the respective authorities as required by the Commissioner exemption. These permission/ approval now produced by the necessary may not be necessary for the purposes of considering registration, as the same had already been filled with Board at the time of affilliation. Nonetheless now these permission / approval are available, there is no point of denying the registration on the pretext of alleged deficiency. - AT
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