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...
Telescoping of commission income already offered was confined to the net income returned and not to the gross profit claimed, where the assessee's business transactions were found to be bogus and commission income was to be estimated on the reported turnover and fresh investments. The recomputation was directed on that basis after reducing the income already declared. Cash deposits during the demonetisation period were held explained by earlier cash withdrawals, supported by date-wise details, bank statements and books of account, so the unexplained-money addition was deleted. Self-assessment tax credit reflected in Form 26AS was directed to be allowed after verification by the AO.
Telescoping of commission income already offered was confined to the net income returned and not to the gross profit claimed, where the assessee's business transactions were found to be bogus and commission income was to be estimated on the reported turnover and fresh investments. The recomputation was directed on that basis after reducing the income already declared. Cash deposits during the demonetisation period were held explained by earlier cash withdrawals, supported by date-wise details, bank statements and books of account, so the unexplained-money addition was deleted. Self-assessment tax credit reflected in Form 26AS was directed to be allowed after verification by the AO.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
