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...
Advances written off were held deductible only if the assessee proves they were advanced for business purposes, became irrecoverable, and satisfy the statutory conditions for bad debt or business loss; because complete particulars were not furnished, the matter was remanded for fresh verification. A claim for correct MAT credit carry forward was admitted in principle before the appellate authority, since a new claim may be raised absent a statutory bar, but computation was sent back for scrutiny. An appeal against a rectification order passed in an assessment made under DRP directions was held maintainable. The rectification dispute was also remitted for fresh consideration because proper opportunity was not given and additional evidence required examination.
Advances written off were held deductible only if the assessee proves they were advanced for business purposes, became irrecoverable, and satisfy the statutory conditions for bad debt or business loss; because complete particulars were not furnished, the matter was remanded for fresh verification. A claim for correct MAT credit carry forward was admitted in principle before the appellate authority, since a new claim may be raised absent a statutory bar, but computation was sent back for scrutiny. An appeal against a rectification order passed in an assessment made under DRP directions was held maintainable. The rectification dispute was also remitted for fresh consideration because proper opportunity was not given and additional evidence required examination.
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