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 u/s 69A - unexplained money - sum received on sale of land co-owned - sale through conveyance deed - year of assessment - it was factually incorrect on the part of the CIT(A) to conclude that the assessee did not offer any reason for holding the cheque and not deposited the same for a long period of time and such conclusion deserves to be quashed. No merit for the addition u/s.69A
Addition u/s 69A - unexplained money - sum received on sale of land co-owned - sale through conveyance deed - year of assessment - it was factually incorrect on the part of the CIT(A) to conclude that the assessee did not offer any reason for holding the cheque and not deposited the same for a long period of time and such conclusion deserves to be quashed. No merit for the addition u/s.69A
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