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...
The assessee, a trust governed by the Government of India, was held eligible for exemption u/s 11 of the Act for arranging credit guarantees to small ventures and supporting business/livelihood development. The ITAT allowed the ground taken by the assessee, following its previous order. The provision for guarantee claims created against outstanding guarantees was treated as an allowable expense, being necessary for providing effective credit guarantees to small and medium enterprises without collateral security through eligible banks as per the scheme.
The assessee, a trust governed by the Government of India, was held eligible for exemption u/s 11 of the Act for arranging credit guarantees to small ventures and supporting business/livelihood development. The ITAT allowed the ground taken by the assessee, following its previous order. The provision for guarantee claims created against outstanding guarantees was treated as an allowable expense, being necessary for providing effective credit guarantees to small and medium enterprises without collateral security through eligible banks as per the scheme.
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