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 unexplained credit u/s 68 - assessee could not produce the party for examination before AO or CIT(A) - balance sheet of the lender clearly shows that the lender have deployed funds are non income producing funds, it does not result into any revenue to that company. The lender clearly is a paper company and nothing more than that - failed to discharge its initial onus as cast upon it u/s 68 - addition sustained
Addition of unexplained credit u/s 68 - assessee could not produce the party for examination before AO or CIT(A) - balance sheet of the lender clearly shows that the lender have deployed funds are non income producing funds, it does not result into any revenue to that company. The lender clearly is a paper company and nothing more than that - failed to discharge its initial onus as cast upon it u/s 68 - addition sustained
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