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...
Additions in the hands of purchaser (Assessee) – It is a common practice that the property is registered on the circle rate and remaining money is paid as “on-money“ - in the absence of any evidence/document, it cannot be applied by closing of the eye - There must be evidence on record to prove that “on-money“ was received from the assessees - HC
Additions in the hands of purchaser (Assessee) – It is a common practice that the property is registered on the circle rate and remaining money is paid as “on-money“ - in the absence of any evidence/document, it cannot be applied by closing of the eye - There must be evidence on record to prove that “on-money“ was received from the assessees - HC
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