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 - Denial of exemption audit report in form 10B was not furnished along with the return of income - audit report was filed by the assessee before the completion of the assessment - the assessee cannot be denied the benefit of exemption for which it is entitled merely on the lapse of procedural requirement i.e. delay in filing the audit report in the prescribed form. - AT
Exemption u/s.11 - Denial of exemption audit report in form 10B was not furnished along with the return of income - audit report was filed by the assessee before the completion of the assessment - the assessee cannot be denied the benefit of exemption for which it is entitled merely on the lapse of procedural requirement i.e. delay in filing the audit report in the prescribed form. - AT
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