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...
Anonymous donations maintained record of identity, address, PAN, Aadhaar details of donors, hence provisions of section 115BBC not applicable. AO doubted genuineness without following procedure, providing opportunity; CIT(A) rightly deleted addition. Tied-up grants not voluntary contributions, not income; no requirement to file Form 9A when application doesn't fall short of 85% income from trust property. AO wrongly added unspent grants shown in balance sheet but not income and expenditure account; CIT(A) correctly deleted addition. No interference required.
Anonymous donations maintained record of identity, address, PAN, Aadhaar details of donors, hence provisions of section 115BBC not applicable. AO doubted genuineness without following procedure, providing opportunity; CIT(A) rightly deleted addition. Tied-up grants not voluntary contributions, not income; no requirement to file Form 9A when application doesn't fall short of 85% income from trust property. AO wrongly added unspent grants shown in balance sheet but not income and expenditure account; CIT(A) correctly deleted addition. No interference required.
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