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...
Revision u/s 263 - CSR expenses - admissibility as the deduction u/s 37(1) - The High Court concurred with the findings of the ITAT that the assessing officer had adequately inquired into the CSR expenses. It affirmed that the expenses were legitimately claimed by the respondent and were not erroneous. The Court emphasized that no substantial question of law arose in this factual matter, leading to the dismissal of the appeal.
Revision u/s 263 - CSR expenses - admissibility as the deduction u/s 37(1) - The High Court concurred with the findings of the ITAT that the assessing officer had adequately inquired into the CSR expenses. It affirmed that the expenses were legitimately claimed by the respondent and were not erroneous. The Court emphasized that no substantial question of law arose in this factual matter, leading to the dismissal of the appeal.
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