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...
Deduction u/s 80P - Failure to file Tax Audit Report - assessee did not submit the audit report as per section 63 of the Karnataka State Co-operative Society Act, 1959 - The omission or wrong statement has not been defined in the Income Tax Act. The assessee was well aware about the business carried on by it and is also aware about the filing of return of income and he has made provision for income tax in its books for preceding assessment years. The assessee will not get the benefit of extended due date for filling return of income as notified - AT
Deduction u/s 80P - Failure to file Tax Audit Report - assessee did not submit the audit report as per section 63 of the Karnataka State Co-operative Society Act, 1959 - The omission or wrong statement has not been defined in the Income Tax Act. The assessee was well aware about the business carried on by it and is also aware about the filing of return of income and he has made provision for income tax in its books for preceding assessment years. The assessee will not get the benefit of extended due date for filling return of income as notified - AT
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