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...
Reassessment jurisdiction was sustained because reasons to believe were recorded and the prescribed statutory procedure was followed. However, additions for alleged unexplained income and expenditure drawn from seized ledger entries could not be made again in another assessee's hands where the ledger owner had accepted the entire recorded amounts and those amounts had already been substantively assessed and confirmed in that person's hands. Corresponding protective additions in the company's hands also could not survive after the substantive additions in the individual's hands were deleted on merits. The challenges to reassessment failed, while the duplicate substantive and related protective additions were deleted.
Reassessment jurisdiction was sustained because reasons to believe were recorded and the prescribed statutory procedure was followed. However, additions for alleged unexplained income and expenditure drawn from seized ledger entries could not be made again in another assessee's hands where the ledger owner had accepted the entire recorded amounts and those amounts had already been substantively assessed and confirmed in that person's hands. Corresponding protective additions in the company's hands also could not survive after the substantive additions in the individual's hands were deleted on merits. The challenges to reassessment failed, while the duplicate substantive and related protective additions were deleted.
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