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...
Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the losses were notional and did not represent actual losses. However, the Appellate Tribunal found that the losses were incurred as part of the appellant's business activities to hedge against foreign exchange fluctuations. The Tribunal relied on established legal principles and previous judgments to support its decision. Therefore, the addition was deleted. - The AO treated the loss on forward contracts as speculative, disallowing it for set-off against profits. However, the Tribunal disagreed, stating that the contracts were entered into to safeguard business interests, not for speculative purposes.
Loss on valuation of foreign exchange contract on M2M basis - Loss on forward contracts - speculative loss - The AO disallowed the addition on the grounds that the losses were notional and did not represent actual losses. However, the Appellate Tribunal found that the losses were incurred as part of the appellant's business activities to hedge against foreign exchange fluctuations. The Tribunal relied on established legal principles and previous judgments to support its decision. Therefore, the addition was deleted. - The AO treated the loss on forward contracts as speculative, disallowing it for set-off against profits. However, the Tribunal disagreed, stating that the contracts were entered into to safeguard business interests, not for speculative purposes.
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