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...
Reopening under section 147 failed because the Assessing Officer merely reproduced Investigation Wing material and third-party statements without independent enquiry or a live nexus to the assessee's alleged escaped income; the notice under section 148 and the reassessment were therefore bad in law. On the addition under section 68, the assessee produced ledger accounts, bank statements, confirmations, returns, financial statements and related memoranda showing advances for land procurement and project development, with the funds routed through banking channels and later repaid. The Tribunal held that these primary documents established identity, creditworthiness and genuineness, and that untested third-party statements could not displace them without specific enquiry. The addition was deleted.
Reopening under section 147 failed because the Assessing Officer merely reproduced Investigation Wing material and third-party statements without independent enquiry or a live nexus to the assessee's alleged escaped income; the notice under section 148 and the reassessment were therefore bad in law. On the addition under section 68, the assessee produced ledger accounts, bank statements, confirmations, returns, financial statements and related memoranda showing advances for land procurement and project development, with the funds routed through banking channels and later repaid. The Tribunal held that these primary documents established identity, creditworthiness and genuineness, and that untested third-party statements could not displace them without specific enquiry. The addition was deleted.
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