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...
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
Rejection of audited books under section 145(3) requires specific defects in the accounts and cannot rest solely on non-compliance with sample third-party notices issued under section 133(6). Where the Assessing Officer verified the supplied particulars and the receipts of an HR outsourcing provider substantially comprised salary and statutory reimbursements as pass-through costs, treating total gross receipts as income and applying a fixed profit rate lacked a rational basis. The estimated addition was therefore arbitrary; deletion by the Commissioner (Appeals) was sustained and the Revenue's appeal was dismissed.
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