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...
Additions u/s 41(1) - Waiver of loan amount - The provisions of section 41(1) are attracted only if some trading liability is written back. - No addition can be made u/s 41(1), when factum of having utilising this amount towards the capital expansion of the assessee’s business is not in dispute and remains unchallenged. - AT
Additions u/s 41(1) - Waiver of loan amount - The provisions of section 41(1) are attracted only if some trading liability is written back. - No addition can be made u/s 41(1), when factum of having utilising this amount towards the capital expansion of the assessee’s business is not in dispute and remains unchallenged. - AT
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