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...
Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.
Royalty payments treated as revenue expenditure, deductible in full; capital expenditure treatment rejected. Bad debt deduction allowed u/s 28, following Supreme Court precedent in Shriram Chits case; Revenue appeal rejected. Division Bench judgment of same Court cited, clarifying expenditure to acquire intangible asset not automatically capital expenditure; enduring nature of benefit key consideration. Appellate orders deleting disallowances upheld by High Court.
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