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...
Assessment of trust - Transaction between the related concerns - Even collectively, the shareholding of the Trustees in ABHSL is far below the threshold of 20%. Hence CIT(A) held that in view of specific provisions of section 13 of the Act he held that ABHSL is not a related party under section 13(3) of the Act and thus addition made by the Assessing Officer is deleted. - Order of CIT(A) confirmed - AT
Assessment of trust - Transaction between the related concerns - Even collectively, the shareholding of the Trustees in ABHSL is far below the threshold of 20%. Hence CIT(A) held that in view of specific provisions of section 13 of the Act he held that ABHSL is not a related party under section 13(3) of the Act and thus addition made by the Assessing Officer is deleted. - Order of CIT(A) confirmed - AT
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