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...
Interest on term loan due from Joint Venture Companies - assessee claimed that the debt is already bad - the AO has noted that the assessee has not written off the loans in its books of account and the same figure is continuing even in subsequent assessment years. Moreover, the assessee itself treated the loan amount as “unsecured considered good” and interest due on the same - Additions confirmed - AT
Interest on term loan due from Joint Venture Companies - assessee claimed that the debt is already bad - the AO has noted that the assessee has not written off the loans in its books of account and the same figure is continuing even in subsequent assessment years. Moreover, the assessee itself treated the loan amount as “unsecured considered good” and interest due on the same - Additions confirmed - AT
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