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...
30% ad-hoc disallowance of travelling expenses being car charges, foreign travelling expenses and domestic travelling expenses - The Assessee argued that the expenses were essential for business expansion and were supported by legal justifications, including past judicial decisions. - The Tribunal concluded that the Lower Authorities erred in making ad-hoc disallowance without disputing the genuineness of the expenses.
30% ad-hoc disallowance of travelling expenses being car charges, foreign travelling expenses and domestic travelling expenses - The Assessee argued that the expenses were essential for business expansion and were supported by legal justifications, including past judicial decisions. - The Tribunal concluded that the Lower Authorities erred in making ad-hoc disallowance without disputing the genuineness of the expenses.
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