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...
On fresh examination of the capital bond agreement, the ITAT found that clause 5 created a binding obligation on the assessee to pay accrued interest to Prestige. Because the bond funds were provided by Prestige and the related interest income had been assessed in the assessee's hands, the corresponding interest liability was deductible as an allowable expenditure. The earlier view that no enforceable obligation existed was rejected, and the disallowance of interest paid to Prestige was directed to be deleted. The appeals were allowed to that extent.
On fresh examination of the capital bond agreement, the ITAT found that clause 5 created a binding obligation on the assessee to pay accrued interest to Prestige. Because the bond funds were provided by Prestige and the related interest income had been assessed in the assessee's hands, the corresponding interest liability was deductible as an allowable expenditure. The earlier view that no enforceable obligation existed was rejected, and the disallowance of interest paid to Prestige was directed to be deleted. The appeals were allowed to that extent.
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