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...
Set off of current year business loss against foreign dividend income - levy of tax u/s 115BBD on gross foreign dividend income - assessee would be entitled for set off of current year loss with the foreign dividend income, assessee would be entitled for set off of brought forward business losses and unabsorbed depreciation of earlier years with the foreign dividend income and assessee would be eligible for deduction u/s 80G of the Act from the Gross Total Income subject to the restrictions provided in that relevant section. - AT
Set off of current year business loss against foreign dividend income - levy of tax u/s 115BBD on gross foreign dividend income - assessee would be entitled for set off of current year loss with the foreign dividend income, assessee would be entitled for set off of brought forward business losses and unabsorbed depreciation of earlier years with the foreign dividend income and assessee would be eligible for deduction u/s 80G of the Act from the Gross Total Income subject to the restrictions provided in that relevant section. - AT
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