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...
TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party. TPO merely rejected the same as Associated Enterprises is located in different geographical locations. It a proper justification by the learned Transfer Pricing Officer to reject the foreign Associated Enterprises as a tested party. - CIT(A) order diciding the issue in favor of assessee is affirmed. - AT
TP Adjustment - Rejection of Associated Enterprises as the tested party - foreign Associated Enterprises satisfied all the criteria for being taken as a tested party. TPO merely rejected the same as Associated Enterprises is located in different geographical locations. It a proper justification by the learned Transfer Pricing Officer to reject the foreign Associated Enterprises as a tested party. - CIT(A) order diciding the issue in favor of assessee is affirmed. - AT
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