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 upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
ITAT upheld rejection of the books under section 145(3) and best judgment assessment under section 144 because the assessee did not furnish complete details or supporting evidence. After rejection of the books, income had to be estimated on a reasonable basis; the Tribunal found the AO's 10% net profit rate unsupported by comparable cases or the assessee's past results and reduced it to 6% of gross turnover, with credit for income already declared. It further held that separate section 68 additions for sundry creditors and unsecured loans could not survive once business income was estimated, absent independent incriminating material, and deleted those additions in full.
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