Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the assessee had with the AE’s to be also at Arm’s Length Price and therefore no adjustment was warranted in the facts and circumstances of the case. - AT
TP Adjustment - where the Tribunal has accepted the international transaction to be at Arm’s Length Price in the hands of AE, then the international transaction that the assessee had with the AE’s to be also at Arm’s Length Price and therefore no adjustment was warranted in the facts and circumstances of the case. - AT
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