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...
Exemption u/s 10(23C)(via) - Solely for philanthropic purposes and not for the purpose of profit - There is nothing wrong if the bonus is paid to the members of the staff, as the staff and other members as well as medical practitioners are not expected to work with the assessee on a charitable basis if a decent hospital is to be maintained and good facilities are to be provided for the patients. It is not the case of the Revenue that the surplus which is generated was diverted to any non-charitable activity. - AT
Exemption u/s 10(23C)(via) - Solely for philanthropic purposes and not for the purpose of profit - There is nothing wrong if the bonus is paid to the members of the staff, as the staff and other members as well as medical practitioners are not expected to work with the assessee on a charitable basis if a decent hospital is to be maintained and good facilities are to be provided for the patients. It is not the case of the Revenue that the surplus which is generated was diverted to any non-charitable activity. - AT
Note: It is a system-generated summary and is for quick reference only.
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