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...
Section 115JB applied to the assessee because the statute does not require a company to be dividend-paying before book profit taxation can be invoked, and the Tribunal applied strict interpretation to reject exclusion on assumption or presumption. It also distinguished precedents cited for earlier assessment years and held that the amended provision effective from 01.04.2012 governed the matter, so the lower appellate view on MAT computation was affirmed. On MAT credit, the year being an abated assessment under section 153A left the assessment open to fresh computation on regular and incriminating material, so the assessee's claim was maintainable in principle and consequential relief was directed to be recomputed.
Section 115JB applied to the assessee because the statute does not require a company to be dividend-paying before book profit taxation can be invoked, and the Tribunal applied strict interpretation to reject exclusion on assumption or presumption. It also distinguished precedents cited for earlier assessment years and held that the amended provision effective from 01.04.2012 governed the matter, so the lower appellate view on MAT computation was affirmed. On MAT credit, the year being an abated assessment under section 153A left the assessment open to fresh computation on regular and incriminating material, so the assessee's claim was maintainable in principle and consequential relief was directed to be recomputed.
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