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 held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer's addition under ICDS VI was deleted and the CIT(A)'s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO's reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue's appeal dismissed.
ITAT held that the notional foreign exchange gain arising on conversion of a Euro loan to a foreign subsidiary as at the balance-sheet date is capital and notional, and therefore not taxable income; the Assessing Officer's addition under ICDS VI was deleted and the CIT(A)'s order upheld. Expenditure incurred to obtain USFDA approval for clinical trials, including costs of supplying both bare and drug-eluting stents, was held to be wholly and exclusively for business under s.37(1) and allowed. The AO's reliance on a lesser notice period under s.148A(b) was found inapplicable on the facts; revenue's appeal dismissed.
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