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 Tribunal upheld denial of deduction under section 80GGC because the donation claimed as political contribution was found to be bogus. It relied on the coordinate bench view in a similar matter involving donations to Samajwadi Party (Secular), and held that the appellate authority had correctly followed that precedent and recorded a factual finding of bogus donation. Finding no legal or factual infirmity in that conclusion, the Tribunal affirmed disallowance of the claim and dismissed the assessee's challenge.
The Tribunal upheld denial of deduction under section 80GGC because the donation claimed as political contribution was found to be bogus. It relied on the coordinate bench view in a similar matter involving donations to Samajwadi Party (Secular), and held that the appellate authority had correctly followed that precedent and recorded a factual finding of bogus donation. Finding no legal or factual infirmity in that conclusion, the Tribunal affirmed disallowance of the claim and dismissed the assessee's challenge.
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