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...
Disallowance u/s 40(a)(ia) - External Development Charges(EDC) paid to HUDA without deduction of tax at source - TDS on EDC u/s 194C/194I - The tribunal concluded that since the EDC payment to HUDA was deposited in the consolidated Fund of the State, no tax deduction was required, thereby affirming the deletion of the disallowance. - The tribunal dismissed the revenue's appeal, upholding the CIT(A)'s order regarding the disallowance of EDC expenditure.
Disallowance u/s 40(a)(ia) - External Development Charges(EDC) paid to HUDA without deduction of tax at source - TDS on EDC u/s 194C/194I - The tribunal concluded that since the EDC payment to HUDA was deposited in the consolidated Fund of the State, no tax deduction was required, thereby affirming the deletion of the disallowance. - The tribunal dismissed the revenue's appeal, upholding the CIT(A)'s order regarding the disallowance of EDC expenditure.
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