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...
Unexplained purchase u/s 69C - alleged that purchase is not genuine and made from bogus biller/ accommodation entry provider - factual finding that no independent material to come to the conclusion that the purchases made by the assessee of gold and silver were either non genuine or that the same were made out of assessee’s known source and purchases were made through banking channel - no question of law arises
Unexplained purchase u/s 69C - alleged that purchase is not genuine and made from bogus biller/ accommodation entry provider - factual finding that no independent material to come to the conclusion that the purchases made by the assessee of gold and silver were either non genuine or that the same were made out of assessee’s known source and purchases were made through banking channel - no question of law arises
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