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...
An intimation under return processing is not a regular assessment, so no opinion was formed and the change-of-opinion objection could not invalidate reopening; the reassessment quashment was set aside and the matter remanded for de novo appellate adjudication. On alleged bogus long-term capital gains from penny stock transactions, the Tribunal held that unrefuted documents showing purchase, demat holding and exchange sale, coupled with the absence of any specific material linking the assessee to entry operators, price rigging or exit providers, could not be displaced by suspicion or human probabilities alone; the additions for unexplained cash credit and related commission were deleted. The same reasoning applied to the later year, and the Revenue's appeal was dismissed.
An intimation under return processing is not a regular assessment, so no opinion was formed and the change-of-opinion objection could not invalidate reopening; the reassessment quashment was set aside and the matter remanded for de novo appellate adjudication. On alleged bogus long-term capital gains from penny stock transactions, the Tribunal held that unrefuted documents showing purchase, demat holding and exchange sale, coupled with the absence of any specific material linking the assessee to entry operators, price rigging or exit providers, could not be displaced by suspicion or human probabilities alone; the additions for unexplained cash credit and related commission were deleted. The same reasoning applied to the later year, and the Revenue's appeal was dismissed.
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