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...
ITAT applied the real income theory to hold that alleged bonus or commission receivable could not be taxed on a due basis where there was no proof of receipt, no employer provisioning, and no document showing a legal right to receive the amount; the deletion of that addition was upheld. On the unexplained money issue, the Tribunal accepted third-party confirmations, agreements, revenue records and section 133(6) responses admitting cash handed over for proposed land transactions, and directed deletion of Rs. 85,00,000. For the remaining cash addition, it held that bare assertions of cash savings and business receipts were insufficient without corroboration, so the relief already granted by the first appellate authority was sustained and no further interference was warranted.
ITAT applied the real income theory to hold that alleged bonus or commission receivable could not be taxed on a due basis where there was no proof of receipt, no employer provisioning, and no document showing a legal right to receive the amount; the deletion of that addition was upheld. On the unexplained money issue, the Tribunal accepted third-party confirmations, agreements, revenue records and section 133(6) responses admitting cash handed over for proposed land transactions, and directed deletion of Rs. 85,00,000. For the remaining cash addition, it held that bare assertions of cash savings and business receipts were insufficient without corroboration, so the relief already granted by the first appellate authority was sustained and no further interference was warranted.
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