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...
The ITAT held that irrecoverable driver and employee balances written off were allowable as business loss, as the facts were identical to an earlier year in the assessee's own case and no distinguishing feature was shown by the Revenue; the disallowance was therefore unsustainable on the principle of consistency. It further held that a bad debt claim cannot be denied merely because the assessee did not prove exhaustive recovery efforts, since after the statutory amendment and the Supreme Court's ruling in TRF Ltd., the governing requirement is write-off in the accounts. The additions on account of both items were directed to be deleted.
The ITAT held that irrecoverable driver and employee balances written off were allowable as business loss, as the facts were identical to an earlier year in the assessee's own case and no distinguishing feature was shown by the Revenue; the disallowance was therefore unsustainable on the principle of consistency. It further held that a bad debt claim cannot be denied merely because the assessee did not prove exhaustive recovery efforts, since after the statutory amendment and the Supreme Court's ruling in TRF Ltd., the governing requirement is write-off in the accounts. The additions on account of both items were directed to be deleted.
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