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...
Unexplained bank credits require credit-wise verification; a difference between aggregate bank deposits and GST-reported turnover does not, by itself, establish unexplained money. The taxpayer must establish the nature and source of credits, while the assessment must examine sales receipts, inter-bank transfers, contra entries, redeposits, expenses and disclosed business results. Business-profit estimation must rely on the nature of trade, prior or later results, comparable cases or other relevant material rather than an arbitrary rate. Consequential penalty requires reconsideration after fresh quantum assessment. A Form 26AS entry showing tax collection on a motor vehicle transaction requires verification of whether the transaction was a purchase or sale before taxing any short-term capital gain.
Unexplained bank credits require credit-wise verification; a difference between aggregate bank deposits and GST-reported turnover does not, by itself, establish unexplained money. The taxpayer must establish the nature and source of credits, while the assessment must examine sales receipts, inter-bank transfers, contra entries, redeposits, expenses and disclosed business results. Business-profit estimation must rely on the nature of trade, prior or later results, comparable cases or other relevant material rather than an arbitrary rate. Consequential penalty requires reconsideration after fresh quantum assessment. A Form 26AS entry showing tax collection on a motor vehicle transaction requires verification of whether the transaction was a purchase or sale before taxing any short-term capital gain.
Note: It is a system-generated summary and is for quick reference only.
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