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 80P - interest income(s) derived from such nationalized/other bank(s) - After examining the provisions of Sec. 80P(2)(d) and relevant legal interpretations, including judicial pronouncements and the CBDT Circular No. 14, the Tribunal concluded that the assessee was entitled to the deduction. Despite conflicting views, the Tribunal favored precedents supporting the assessee's position.
Deduction u/s 80P - interest income(s) derived from such nationalized/other bank(s) - After examining the provisions of Sec. 80P(2)(d) and relevant legal interpretations, including judicial pronouncements and the CBDT Circular No. 14, the Tribunal concluded that the assessee was entitled to the deduction. Despite conflicting views, the Tribunal favored precedents supporting the assessee's position.
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