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...
The Tribunal reiterated that the amendment enhancing the tax rate under section 115BBE is substantive and applies prospectively. Income surrendered in a survey conducted before the amendment therefore remained taxable only at the rate then in force, not at the enhanced rate introduced later. Relying on binding jurisdictional precedent, it held that where the survey occurred on 22.09.2016, the Revenue could not apply the amended special rate to the surrendered income. The impugned addition was directed to be deleted.
The Tribunal reiterated that the amendment enhancing the tax rate under section 115BBE is substantive and applies prospectively. Income surrendered in a survey conducted before the amendment therefore remained taxable only at the rate then in force, not at the enhanced rate introduced later. Relying on binding jurisdictional precedent, it held that where the survey occurred on 22.09.2016, the Revenue could not apply the amended special rate to the surrendered income. The impugned addition was directed to be deleted.
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