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 set aside the CIT(A) order and restored the case to the file of the AO/TPO for de novo adjudication, holding that neither the assessee's nor the TPO's CUP comparables met Rule 10B(2)/(3) comparability standards; the AO/TPO is directed to reassess ALP after identifying or constructing reliable comparables and making appropriate adjustments (including for convertibility/option value, subordination, security, industry risk and coupon structure). The Tribunal also remitted disputed legal/professional, advertising and commission expenses to the AO for verification and determination as capitalisable WIP or allowable revenue expenditure. The Revenue's appeal is allowed for statistical purposes.
ITAT set aside the CIT(A) order and restored the case to the file of the AO/TPO for de novo adjudication, holding that neither the assessee's nor the TPO's CUP comparables met Rule 10B(2)/(3) comparability standards; the AO/TPO is directed to reassess ALP after identifying or constructing reliable comparables and making appropriate adjustments (including for convertibility/option value, subordination, security, industry risk and coupon structure). The Tribunal also remitted disputed legal/professional, advertising and commission expenses to the AO for verification and determination as capitalisable WIP or allowable revenue expenditure. The Revenue's appeal is allowed for statistical purposes.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4798
Join Channel
TaxTMI 
