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...
Disallowance of provision for fraud - AO and CIT(A) doubting the type of expenditure has observed that out of total expenditure for the year 1/5th is to be disallowed - this is a regular feature of the assessee bank to make provision for fraud and the actual expenditure incurred are cleared from the balance appearing in the account of provision for fraud - full claim allowed - AT
Disallowance of provision for fraud - AO and CIT(A) doubting the type of expenditure has observed that out of total expenditure for the year 1/5th is to be disallowed - this is a regular feature of the assessee bank to make provision for fraud and the actual expenditure incurred are cleared from the balance appearing in the account of provision for fraud - full claim allowed - AT
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