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...
Bogus purchases - profit estimation on alleged party @ 12.50% - no material to substantiate the view taken by the AO - comparing the GP rate on other purchases and overall G.P rate declared, it was held that assessee is operating on low margin, hence the rate of G.P should be at rate earned from other purchases
Bogus purchases - profit estimation on alleged party @ 12.50% - no material to substantiate the view taken by the AO - comparing the GP rate on other purchases and overall G.P rate declared, it was held that assessee is operating on low margin, hence the rate of G.P should be at rate earned from other purchases
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