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...
Genuineness of purchases - non compliance of notices u/s 133(6) - non of entities declared as Hawala/Bogus dealers by any of the authorities - assessee was able to produce overwhelming documents to substantiate the purchase - same can not be disallowed only on ground that notices u/s 133(6) were not responded to, which was also not within the control of the assessee - purchases allowed
Genuineness of purchases - non compliance of notices u/s 133(6) - non of entities declared as Hawala/Bogus dealers by any of the authorities - assessee was able to produce overwhelming documents to substantiate the purchase - same can not be disallowed only on ground that notices u/s 133(6) were not responded to, which was also not within the control of the assessee - purchases allowed
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