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...
Disallowance of commission expenses paid by the assessee to its related concern - the fact that the assessee deducted tax at source and both the companies are falling under maximum marginal rate of tax, does not satisfy the requirement of reasonableness of expenditure qua the services alleged to be received by the assessee. All the above aspects were neither examined by the AO nor by the CIT(A) and appeal filed by the assessee was allowed vide impugned order without even calling for any remand report, in this regard, from the AO. - Matter restored back - AT
Disallowance of commission expenses paid by the assessee to its related concern - the fact that the assessee deducted tax at source and both the companies are falling under maximum marginal rate of tax, does not satisfy the requirement of reasonableness of expenditure qua the services alleged to be received by the assessee. All the above aspects were neither examined by the AO nor by the CIT(A) and appeal filed by the assessee was allowed vide impugned order without even calling for any remand report, in this regard, from the AO. - Matter restored back - AT
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