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...
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
Proper service of notice will not vitiate an appellate order unless actual prejudice is shown, and the Tribunal found no such prejudice where notices were issued through the ITBA system and multiple opportunities were granted. Rejection of books of account under section 145(3) was upheld because salary es lacked primary records, creditors remained unverified, stock discrepancies were found, and complete supporting evidence was not produced. Once the books were rejected, income estimation followed, and the Tribunal sustained the net profit rate adopted on the basis of past history, industry practice and the defects in the accounts, rejecting the challenge as unsupported.
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