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 in respect of gift and donation given to third parties - It is just like a donation or in the nature of gift, which cannot be allowed u/s 37. However, we make it clear that if the assessee produce necessary details to claim exemption u/s 80G of the Act, the same may be examined and exemption u/s 80G may be granted after verifying the relevant details from the receipt issued by the respective party. - AT
Disallowance in respect of gift and donation given to third parties - It is just like a donation or in the nature of gift, which cannot be allowed u/s 37. However, we make it clear that if the assessee produce necessary details to claim exemption u/s 80G of the Act, the same may be examined and exemption u/s 80G may be granted after verifying the relevant details from the receipt issued by the respective party. - AT
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