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...
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
Cessation of liability u/s 41(1) - Notice issued u/s 133(6) could not be served upon the creditors - while the assessee has continued to declare the trading liability in its books of account, no benefit can be said to have been obtained in respect of such trading liability by way of remission or cessation thereof and thus the requirement of Section 41(1) are not satisfied - The additions made u/s 41(1) set aside and reversed. - AT
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