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 as perquisite u/s 17(2)(iv) - payment for credit card bills made by the company on her behalf - The ITAT deleted the addition accepting the assessee's contention that the expenses were for business purposes and not personal perquisites. This decision was made considering the evidence provided by the assessee demonstrating the nature of the expenses incurred in connection with the business.
Addition as perquisite u/s 17(2)(iv) - payment for credit card bills made by the company on her behalf - The ITAT deleted the addition accepting the assessee's contention that the expenses were for business purposes and not personal perquisites. This decision was made considering the evidence provided by the assessee demonstrating the nature of the expenses incurred in connection with the business.
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