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 - DIT(E) cancelled the registration u/s 12AA of the Act on the ground that the assessee violated the provision of section 13(3) of the Act for taking loan and donating the same to the sister concern without carrying out any charitable activity - - Undisputedly, the words as obtained registration at any time was inserted in section 12AA(3) of the Act w.e.f 01.06.2010. DIT(E) has cancelled the registration since inception - as contended by assessee that the cancellation could not have been made prior to the insertion of the provision thus, the DIT(E) clearly exceeded the jurisdiction. - AT
Exemption u/s 11 - DIT(E) cancelled the registration u/s 12AA of the Act on the ground that the assessee violated the provision of section 13(3) of the Act for taking loan and donating the same to the sister concern without carrying out any charitable activity - - Undisputedly, the words as obtained registration at any time was inserted in section 12AA(3) of the Act w.e.f 01.06.2010. DIT(E) has cancelled the registration since inception - as contended by assessee that the cancellation could not have been made prior to the insertion of the provision thus, the DIT(E) clearly exceeded the jurisdiction. - AT
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