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...
Addition u/s 68 - capital introduced by the partners - disallowed the interest paid to the partners - if at all, if the respondent-Department was not satisfied with the explanation, it was for them to have got it verified from the partners. Rather than still pursuing the matter before the appellant’s partnership firm, which is otherwise impermissible. - Order of ITAT against the assessee quashed - HC
Addition u/s 68 - capital introduced by the partners - disallowed the interest paid to the partners - if at all, if the respondent-Department was not satisfied with the explanation, it was for them to have got it verified from the partners. Rather than still pursuing the matter before the appellant’s partnership firm, which is otherwise impermissible. - Order of ITAT against the assessee quashed - HC
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