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 to the book profit u/s 115JB for the amount disallowed u/s 14A r.w. Rule 8D - the tribunal noted that the AO had made the disallowance under Section 14A, but the assessee hadn't adjusted this amount while computing the book profit. The tribunal upheld the addition to the book profit, affirming the decision of the CIT(A) and partly allowing the Revenue's appeal on this ground.
Addition to the book profit u/s 115JB for the amount disallowed u/s 14A r.w. Rule 8D - the tribunal noted that the AO had made the disallowance under Section 14A, but the assessee hadn't adjusted this amount while computing the book profit. The tribunal upheld the addition to the book profit, affirming the decision of the CIT(A) and partly allowing the Revenue's appeal on this ground.
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