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 sales promotion expenses - Payment to Doctors / medical practitioners - Assessee has not submitted any technical record or any agreement entered with those doctors to carry out this kind of activities which can prove that these doctors have done or carried out certain services to the assessee. In the absence of any documentary evidences or cogent material in support of the assessee’s claim, we are inclined to reject the same. - AT
Addition of sales promotion expenses - Payment to Doctors / medical practitioners - Assessee has not submitted any technical record or any agreement entered with those doctors to carry out this kind of activities which can prove that these doctors have done or carried out certain services to the assessee. In the absence of any documentary evidences or cogent material in support of the assessee’s claim, we are inclined to reject the same. - AT
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