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...
Delayed employer’s contributions to pension fund - provisions of section 43B of the Act would not be applicable to the assessee and even in the worse case scenario, the provisions of section 43B of the Act were to be applied, then the contribution would be considered as paid as the account was maintained by WBPDCL which is extended arm or instrumentality of the State Govt only. - AT
Delayed employer’s contributions to pension fund - provisions of section 43B of the Act would not be applicable to the assessee and even in the worse case scenario, the provisions of section 43B of the Act were to be applied, then the contribution would be considered as paid as the account was maintained by WBPDCL which is extended arm or instrumentality of the State Govt only. - AT
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