12,131 results for “disallowance”+ Section 12clear
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In the result, appeals filed by the Revenue are partly allowed
Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar
Section 40A(2) and Chapter X-A. The assessee must establish: (a) The operating costs were arm's length (b) The apportionment to assessee was arm's length (c) Documentation was contemporaneously maintained The assessee has failed on all three counts. The vague "mutually agreed" language in the MOU, the absence of detailed cost accounting, and the unreconciled difference