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 11 - registration u/s 12AB and approval u/s 80G(5) denied - The apprehension of revenue that the loans would be given to a related or favourable party is a heighted apprehension. - If the trust makes any such loan in future, the law provides for forfeiture of exemption u/s 13 which in case of necessity, can be invoked by authorities. - CIT(E) directed to consider the application of assessee - AT
Exemption u/s 11 - registration u/s 12AB and approval u/s 80G(5) denied - The apprehension of revenue that the loans would be given to a related or favourable party is a heighted apprehension. - If the trust makes any such loan in future, the law provides for forfeiture of exemption u/s 13 which in case of necessity, can be invoked by authorities. - CIT(E) directed to consider the application of assessee - AT
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