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...
Administrative and establishment expenses incurred to keep a co-operative society in existence, meet statutory compliance, and preserve its affairs were held deductible against interest income on a real-income basis; the Tribunal also noted that any related business loss could be set off against income under another head. The disallowance was deleted. On self-assessment tax, the Tribunal found that credit had been given only for TDS despite payment of self-assessment tax, treated the omission as a mistake apparent from the record, and directed verification and grant of credit. The appeal was partly allowed.
Administrative and establishment expenses incurred to keep a co-operative society in existence, meet statutory compliance, and preserve its affairs were held deductible against interest income on a real-income basis; the Tribunal also noted that any related business loss could be set off against income under another head. The disallowance was deleted. On self-assessment tax, the Tribunal found that credit had been given only for TDS despite payment of self-assessment tax, treated the omission as a mistake apparent from the record, and directed verification and grant of credit. The appeal was partly allowed.
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