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 u/s. 40A(3) - business expediency in payment of cash towards genuine transaction - The contention of the assessee from the day one is that the sellers demanded the assessee to pay in cash which is part and parcel of total sale consideration.There is no dispute with regard to identification of the sellers as well as their confirmations in respect of payment in cash from the assessee. - The sellers also admitted the payment of cash before the registering authority under due process. - Additions deleted - AT
Disallowance u/s. 40A(3) - business expediency in payment of cash towards genuine transaction - The contention of the assessee from the day one is that the sellers demanded the assessee to pay in cash which is part and parcel of total sale consideration.There is no dispute with regard to identification of the sellers as well as their confirmations in respect of payment in cash from the assessee. - The sellers also admitted the payment of cash before the registering authority under due process. - Additions deleted - AT
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