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...
Taxability of income in India - Addition of receipt emanating from offshore supplies of escalators and elevators - The Appellate Tribunal observed that the consortium, comprising the appellant and another entity, had distinct and separate responsibilities delineated in the Memorandum of Understanding (MOU). The Tribunal emphasized that the income accrued to the appellant from offshore supplies, and as per relevant legal precedents, such income was not taxable in India. Therefore, the Tribunal directed the assessing officer to delete the addition made to the appellant's income.
Taxability of income in India - Addition of receipt emanating from offshore supplies of escalators and elevators - The Appellate Tribunal observed that the consortium, comprising the appellant and another entity, had distinct and separate responsibilities delineated in the Memorandum of Understanding (MOU). The Tribunal emphasized that the income accrued to the appellant from offshore supplies, and as per relevant legal precedents, such income was not taxable in India. Therefore, the Tribunal directed the assessing officer to delete the addition made to the appellant's income.
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