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 undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
Addition of undisclosed income u/s 69B - purchase of share from its directors and their closely held companies - nothing on record would demonstrate any exchange / flow of funds, out of books, between the assessee and the sellers - in the absence of any evidences establishing receipts & payments outside regular books of accounts, the provisions of Section 69B could not be invoked - addition deleted
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