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...
Assessment u/s 153A - Addition u/s 68 - the burden had shifted to revenue to show the basis of some reliable and tangible material which could indicate undisclosed receipts out of books of accounts in the hands of assessee. - we cannot improve upon what AO could have done himself - addition made by AO on account of alleged receipts of cash deleted.
Assessment u/s 153A - Addition u/s 68 - the burden had shifted to revenue to show the basis of some reliable and tangible material which could indicate undisclosed receipts out of books of accounts in the hands of assessee. - we cannot improve upon what AO could have done himself - addition made by AO on account of alleged receipts of cash deleted.
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