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...
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
Prior-period expenditure may be considered for the correct assessment year where its genuineness is undisputed and the surrounding circumstances support the claim. The text notes that the expenditure was not disputed by the revenue and, because the assessee was a public company, the court directed that the claim be examined for AY 2003-04 if a revised computation was filed within the stated time. The operative effect is that the assessee was permitted to seek consideration of the expenditure in the appropriate year, rather than having the claim rejected on the basis of timing alone.
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