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 of 'on money' for the sale of the property u/s 69 - addition based on seller statement - no mention as to cross examination of the seller - no valuation of the property - specification of particular activities carried out by the vendors for earning income - appropriate to remand back to AO for verification
Addition of 'on money' for the sale of the property u/s 69 - addition based on seller statement - no mention as to cross examination of the seller - no valuation of the property - specification of particular activities carried out by the vendors for earning income - appropriate to remand back to AO for verification
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