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...
Validity of assessment order - The tribunal questioned the effectiveness and fairness of the assessment procedure, particularly the timing and practicality of issuing notices and summonses to recipients across different locations within a short timeframe. It criticized the Assessing Officer's dormant approach followed by hurried completion of proceedings. - The ITAT held that, we are satisfied that these expenses were incurred for the business purposes during the course of business. The assessee has submitted all basic details. - Additions deleted.
Validity of assessment order - The tribunal questioned the effectiveness and fairness of the assessment procedure, particularly the timing and practicality of issuing notices and summonses to recipients across different locations within a short timeframe. It criticized the Assessing Officer's dormant approach followed by hurried completion of proceedings. - The ITAT held that, we are satisfied that these expenses were incurred for the business purposes during the course of business. The assessee has submitted all basic details. - Additions deleted.
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