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...
TP adjustment - intra-group services - Infrastructure consultancy and support charges - DR was unable to controvert the factual finding of the DRP that infrastructure and consultancy services were for development of a new plant in Sanand - these services cannot be held to be supervisory and stewardship services rendered by the AE to the assessee, as contended by the TPO and as argued by the ld.DR before us. - No TP additions - AT
TP adjustment - intra-group services - Infrastructure consultancy and support charges - DR was unable to controvert the factual finding of the DRP that infrastructure and consultancy services were for development of a new plant in Sanand - these services cannot be held to be supervisory and stewardship services rendered by the AE to the assessee, as contended by the TPO and as argued by the ld.DR before us. - No TP additions - AT
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