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...
DSIR certification supported deduction under section 35(2AB) because the Tribunal applied judicial consistency and held that the Assessing Officer could not disregard the certified R&D expenditure without following the statutory procedure. It also sustained deletion of manufacturing-expense and R&D additions made on post-survey extrapolation, finding no abnormality in the expense ratio and no rebuttal of the factual findings. As those disallowances failed on merits, the reassessment based on the same grounds was held invalid. For the later year, interest disallowance linked to a loan treated as unexplained cash credit was deleted once that underlying addition no longer survived, while other claims were sent back for factual verification.
DSIR certification supported deduction under section 35(2AB) because the Tribunal applied judicial consistency and held that the Assessing Officer could not disregard the certified R&D expenditure without following the statutory procedure. It also sustained deletion of manufacturing-expense and R&D additions made on post-survey extrapolation, finding no abnormality in the expense ratio and no rebuttal of the factual findings. As those disallowances failed on merits, the reassessment based on the same grounds was held invalid. For the later year, interest disallowance linked to a loan treated as unexplained cash credit was deleted once that underlying addition no longer survived, while other claims were sent back for factual verification.
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