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...
Deduction u/s 80IA - If an assessee is entitled to certain deductions under the provisions of the Income Tax Act, the same should not be disallowed, merely because of any bona fide mistake or error on the part of the taxpayer, rather, the Income Tax Authorities should assist the concerned assessees in filing their correct returns of income. This is not the case of the Department that the assessee was not entitled to the deduction claimed u/s 80IA. - AT
Deduction u/s 80IA - If an assessee is entitled to certain deductions under the provisions of the Income Tax Act, the same should not be disallowed, merely because of any bona fide mistake or error on the part of the taxpayer, rather, the Income Tax Authorities should assist the concerned assessees in filing their correct returns of income. This is not the case of the Department that the assessee was not entitled to the deduction claimed u/s 80IA. - AT
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