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 10 B - The AO argued that the units were formed by the transfer of previously used machinery, disqualifying them from certain deductions. - The tribunal, however, noted that the CIT(A) had provided a detailed examination of the history and operations of these units, establishing that they were indeed new undertakings that satisfied the statutory requirements for the deduction under Section 10B. - One of the significant issues was whether the sales proceeds of exported goods were received in India within the prescribed time frame to qualify for exemptions under Section 10B. The tribunal found that despite minor discrepancies in documentation, the majority of proceeds were indeed received within the permissible period, thus supporting the assessee's claim for deduction.
Deduction u/s 10 B - The AO argued that the units were formed by the transfer of previously used machinery, disqualifying them from certain deductions. - The tribunal, however, noted that the CIT(A) had provided a detailed examination of the history and operations of these units, establishing that they were indeed new undertakings that satisfied the statutory requirements for the deduction under Section 10B. - One of the significant issues was whether the sales proceeds of exported goods were received in India within the prescribed time frame to qualify for exemptions under Section 10B. The tribunal found that despite minor discrepancies in documentation, the majority of proceeds were indeed received within the permissible period, thus supporting the assessee's claim for deduction.
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