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...
Assessee lent money from borrowed funds, charging higher interest rate than paid, later lending from own funds. Total interest paid eligible for deduction, though assessee suo moto disallowed part. No further disallowance warranted by authorities. Maturity proceeds from keyman insurance policy exempt u/s 10(10D), without bifurcation, following precedent. Authorities erred in denying exemption. Decisions favored assessee on both issues.
Assessee lent money from borrowed funds, charging higher interest rate than paid, later lending from own funds. Total interest paid eligible for deduction, though assessee suo moto disallowed part. No further disallowance warranted by authorities. Maturity proceeds from keyman insurance policy exempt u/s 10(10D), without bifurcation, following precedent. Authorities erred in denying exemption. Decisions favored assessee on both issues.
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