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...
Addition being the difference in receipts as per the Profit and Loss Account and as per AS-26 - addition was made solely based on the AIR information without bringing any cogent evidence on record to suggest that the assessee received income from the said parties especially when the assessee is denying any transactions with those parties - addition directed to be deleted - AT
Addition being the difference in receipts as per the Profit and Loss Account and as per AS-26 - addition was made solely based on the AIR information without bringing any cogent evidence on record to suggest that the assessee received income from the said parties especially when the assessee is denying any transactions with those parties - addition directed to be deleted - AT
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