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...
Income from pension fund u/s 10(23AAB) - CIT(A) admitted the fresh claim - Claim of exemption when the income is taxable u/s 44 - If the assessee failed to revise its claim by way of revised return of income, for any reason whatsoever, the assessee is not estopped to make correct claim by way of revised computation. The revised claim can be entertained in appellate proceedings. We find no infirmity in the action of CIT(A) to allow revised enhanced claim. - AT
Income from pension fund u/s 10(23AAB) - CIT(A) admitted the fresh claim - Claim of exemption when the income is taxable u/s 44 - If the assessee failed to revise its claim by way of revised return of income, for any reason whatsoever, the assessee is not estopped to make correct claim by way of revised computation. The revised claim can be entertained in appellate proceedings. We find no infirmity in the action of CIT(A) to allow revised enhanced claim. - AT
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