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...
Only the profit element embedded in on-money receipts was held taxable, because the Tribunal examined the assessee's disclosed receipts, profit and loss account, gross revenue and project cost, and found that taxing the entire on-money would create an unrealistically high net profit ratio for the real estate business. The Tribunal therefore treated the receipts as containing profit only and, on estimate, enhanced the addition from 20% to 40%. The High Court held this to be a factual appreciation and estimation exercise, not a substantial question of law. Both the Revenue's challenge for full addition and the assessee's challenge to the higher estimate were rejected.
Only the profit element embedded in on-money receipts was held taxable, because the Tribunal examined the assessee's disclosed receipts, profit and loss account, gross revenue and project cost, and found that taxing the entire on-money would create an unrealistically high net profit ratio for the real estate business. The Tribunal therefore treated the receipts as containing profit only and, on estimate, enhanced the addition from 20% to 40%. The High Court held this to be a factual appreciation and estimation exercise, not a substantial question of law. Both the Revenue's challenge for full addition and the assessee's challenge to the higher estimate were rejected.
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