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 upheld the deletion of the addition relating to a notional foreign-exchange loss on restatement of liabilities and assets, finding the assessee had pleaded and reconciled contract liabilities and applied AS-11 such that the alleged loss was revenue in nature and properly accrued; the CIT(A)'s deletion was affirmed. ITAT also affirmed deletion of the disallowance for interest on a residential property, accepting its inclusion in the relevant block of assets. The Tribunal partly sustained the Revenue on directors' foreign-travel expenses, imposing an additional disallowance of Rs.2,00,000 above the disallowed Rs.51,20,000. The section 14A read with Rule 8D addition was deleted for want of AO's satisfaction and proof of nexus.
ITAT upheld the deletion of the addition relating to a notional foreign-exchange loss on restatement of liabilities and assets, finding the assessee had pleaded and reconciled contract liabilities and applied AS-11 such that the alleged loss was revenue in nature and properly accrued; the CIT(A)'s deletion was affirmed. ITAT also affirmed deletion of the disallowance for interest on a residential property, accepting its inclusion in the relevant block of assets. The Tribunal partly sustained the Revenue on directors' foreign-travel expenses, imposing an additional disallowance of Rs.2,00,000 above the disallowed Rs.51,20,000. The section 14A read with Rule 8D addition was deleted for want of AO's satisfaction and proof of nexus.
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