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 of VAT expenses - Disallowance as "fee" or "charge" u/s40(a)(iib) - The Assessee, a state government-owned company engaged in the wholesale business of foreign liquor in Chhattisgarh, contested the disallowance. - Referring to the judgment of the Hon’ble Supreme Court in the case of Kerala State Beverages Manufacturing & Marketing Corporation Ltd., the Tribunal held that surcharge on sales tax, including VAT, does not fall within the scope of disallowance under Section 40(a)(iib) of the Income-tax Act, 1961.
Disallowance of VAT expenses - Disallowance as "fee" or "charge" u/s40(a)(iib) - The Assessee, a state government-owned company engaged in the wholesale business of foreign liquor in Chhattisgarh, contested the disallowance. - Referring to the judgment of the Hon’ble Supreme Court in the case of Kerala State Beverages Manufacturing & Marketing Corporation Ltd., the Tribunal held that surcharge on sales tax, including VAT, does not fall within the scope of disallowance under Section 40(a)(iib) of the Income-tax Act, 1961.
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