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 provision for slow moving obsolete stock - if the provision is accounted in accordance with the statutory requirements and the method of accounting has been consistently followed by the assessee over a period of time and accepted by the Department, the same should not be disturbed. - In the instant case no contrary material has been brought on record by the Department to show that the assessee was not consistently following accounting policy and provision for slow moving and obsolete inventory in preceding or succeeding assessment years - Additions deleted - AT
Disallowance of provision for slow moving obsolete stock - if the provision is accounted in accordance with the statutory requirements and the method of accounting has been consistently followed by the assessee over a period of time and accepted by the Department, the same should not be disturbed. - In the instant case no contrary material has been brought on record by the Department to show that the assessee was not consistently following accounting policy and provision for slow moving and obsolete inventory in preceding or succeeding assessment years - Additions deleted - AT
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