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...
ITAT adjudicated two key issues involving tax treatment of commercial transactions. First, regarding interest disallowance under section 36(1)(iii), the Tribunal held that loans advanced to third parties constituted genuine commercial transactions. Despite non-recovery of interest, the Tribunal found no evidence of fund diversion, ruling in favor of the assessee. Second, concerning melting charges, the Tribunal set aside the addition based on estimated melting gain, directing the Assessing Officer to delete the addition, respecting the assessee's maintained accounting records and following precedent from a prior assessment year. Both substantive issues were resolved in the assessee's favor, emphasizing commercial reasonableness and proper accounting practices.
ITAT adjudicated two key issues involving tax treatment of commercial transactions. First, regarding interest disallowance under section 36(1)(iii), the Tribunal held that loans advanced to third parties constituted genuine commercial transactions. Despite non-recovery of interest, the Tribunal found no evidence of fund diversion, ruling in favor of the assessee. Second, concerning melting charges, the Tribunal set aside the addition based on estimated melting gain, directing the Assessing Officer to delete the addition, respecting the assessee's maintained accounting records and following precedent from a prior assessment year. Both substantive issues were resolved in the assessee's favor, emphasizing commercial reasonableness and proper accounting practices.
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