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...
Addition of interest income under the head ‘income from other sources’ while computing tonnage tax u/s.115VI - The question whether the assessee had maintained separate books of accounts or not is irrelevant to decide the nature and head of income. Therefore, we are of the considered view that interest income earned by the assessee from deposits is not an income derived from shipping business and thus, the same is not entitled for tonnage tax scheme. - AT
Addition of interest income under the head ‘income from other sources’ while computing tonnage tax u/s.115VI - The question whether the assessee had maintained separate books of accounts or not is irrelevant to decide the nature and head of income. Therefore, we are of the considered view that interest income earned by the assessee from deposits is not an income derived from shipping business and thus, the same is not entitled for tonnage tax scheme. - AT
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