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...
Ad-hoc disallowance at the rate of 10% on credit card expenses - Prima Facie the said disallowance is ad-hoc in nature. AO ought to have made reference to any of such expenses given in the books which could indicate that they are personal in nature. Merely making disallowance just for the sake of concluding the assessment is not a justified approach. Expenses through credit card have been claimed as general business expenditure in order to attend the business meetings. - AT
Ad-hoc disallowance at the rate of 10% on credit card expenses - Prima Facie the said disallowance is ad-hoc in nature. AO ought to have made reference to any of such expenses given in the books which could indicate that they are personal in nature. Merely making disallowance just for the sake of concluding the assessment is not a justified approach. Expenses through credit card have been claimed as general business expenditure in order to attend the business meetings. - AT
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