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...
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
Best judgment assessment in a civil contract business must rest on a fair estimate with nexus to available material; a flat 15 per cent profit rate was found arbitrary on the facts, and business income was directed to be recomputed at 7 per cent of turnover. The Tribunal also held that claims for Chapter VI-A deductions and credits for TDS and self-assessment tax could not be decided on the existing record because supporting documents and reconciliations were incomplete, so the matter was remitted for verification and grant of eligible relief in accordance with law.
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