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...
Revision u/s 263 by CIT - Value Added Tax paid by assessee and claimed as deduction u/s.37 r.w.s. 43B or u/s 40(a)(iib) - scope of amended provisions of section 40(a)(iib) - royalty, licence fee, service fee, privilege fee, service charge or not - VAT collected and paid by TASMAC under the provisions of TamilNadu Tax Act, 2006 is an allowable expenditure and cannot be disallowed under the amended provisions of section 40(a)(iib) - AT
Revision u/s 263 by CIT - Value Added Tax paid by assessee and claimed as deduction u/s.37 r.w.s. 43B or u/s 40(a)(iib) - scope of amended provisions of section 40(a)(iib) - royalty, licence fee, service fee, privilege fee, service charge or not - VAT collected and paid by TASMAC under the provisions of TamilNadu Tax Act, 2006 is an allowable expenditure and cannot be disallowed under the amended provisions of section 40(a)(iib) - AT
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