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...
Claim of deduction of unknown liability towards customs duty - Deduction u/s 43B - Fresh claim before AO during the course of assessment proceedings - Since the assessee was not legally obliged to pay customs duty amount, therefore, this additional claim towards payment of customs duty cannot be allowed under the provision of Section 43B(a) of the Act. - AT
Claim of deduction of unknown liability towards customs duty - Deduction u/s 43B - Fresh claim before AO during the course of assessment proceedings - Since the assessee was not legally obliged to pay customs duty amount, therefore, this additional claim towards payment of customs duty cannot be allowed under the provision of Section 43B(a) of the Act. - AT
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