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...
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
Business expenditure claims for shortages and quality cuts were sent back for fresh verification because the lower authorities had rejected them for want of complete supporting evidence, while the Tribunal found no corroboration for the assumption that the goods remained in closing stock and noted that additional material had not yet been examined. The transfer pricing adjustment under the CUP method was also remanded because a disputed credit note appeared to involve only a clerical date error, and the revised arm's length computation with discounts and credit notes required verification. The omitted TDS credit was ordered to be granted because it had been acknowledged in the draft computation and was not denied by any DRP direction.
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