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 - Charitable activity or not - printing of News papers to educate the Toiling Masses being its objects - Tribunal has not rendered any finding on the correctness of the decision of the CIT(A), which examined the factual aspects as to purpose behind which the newspaper was printed and published. Therefore, merely by applying the decision in Al-Madeena Charitable Trust(cited supra), the order passed by the CITA could not have been reversed. - HC
Exemption u/s 11 - Charitable activity or not - printing of News papers to educate the Toiling Masses being its objects - Tribunal has not rendered any finding on the correctness of the decision of the CIT(A), which examined the factual aspects as to purpose behind which the newspaper was printed and published. Therefore, merely by applying the decision in Al-Madeena Charitable Trust(cited supra), the order passed by the CITA could not have been reversed. - HC
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