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...
Deduction u/s 80IA - The Revenue contended that the filing of Form 10CCB within the prescribed date is mandatory, while the assessee argued otherwise. The Tribunal, after analyzing the relevant legal provisions, concluded that while the filing of Form 10CCB is mandatory, adhering to the prescribed due date is not. The Tribunal also noted that the CIT(A) failed to properly consider legal precedents and independently assess the facts of the case. Consequently, the Tribunal set aside the CIT(A)'s decision and remanded the matter for fresh consideration.
Deduction u/s 80IA - The Revenue contended that the filing of Form 10CCB within the prescribed date is mandatory, while the assessee argued otherwise. The Tribunal, after analyzing the relevant legal provisions, concluded that while the filing of Form 10CCB is mandatory, adhering to the prescribed due date is not. The Tribunal also noted that the CIT(A) failed to properly consider legal precedents and independently assess the facts of the case. Consequently, the Tribunal set aside the CIT(A)'s decision and remanded the matter for fresh consideration.
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