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...
Documentary evidence supporting purchases, including invoices, e-way bills, bank records, KYC documents, transporter details, receipts, photographs and GST returns, was accepted as unrebutted because no discrepancy or fabrication was shown. The Tribunal held that mere suspicion that such material could be manufactured was insufficient, and that alleged bogus purchases and grey-market purchases must be tested on different parameters. Where documentary proof is produced, it can be displaced only by independent enquiry or material showing lower-price availability and inflation of bills. In the absence of such rebuttal, the estimated profit addition for alleged non-genuine purchases was unsustainable and deleted.
Documentary evidence supporting purchases, including invoices, e-way bills, bank records, KYC documents, transporter details, receipts, photographs and GST returns, was accepted as unrebutted because no discrepancy or fabrication was shown. The Tribunal held that mere suspicion that such material could be manufactured was insufficient, and that alleged bogus purchases and grey-market purchases must be tested on different parameters. Where documentary proof is produced, it can be displaced only by independent enquiry or material showing lower-price availability and inflation of bills. In the absence of such rebuttal, the estimated profit addition for alleged non-genuine purchases was unsustainable and deleted.
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