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 share capital u/s 68 - source of source - all the three conditions as required u/s. 68 i.e. the identity, creditworthiness and genuineness of the transaction were placed before the ld AO and the onus shifted to the ld AO to disprove the materials placed before him - Without doing so, the addition, based on conjectures and surmises cannot be justified.
Addition of share capital u/s 68 - source of source - all the three conditions as required u/s. 68 i.e. the identity, creditworthiness and genuineness of the transaction were placed before the ld AO and the onus shifted to the ld AO to disprove the materials placed before him - Without doing so, the addition, based on conjectures and surmises cannot be justified.
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