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...
Assessment u/s 153A - Addition u/s 41(1) - No material was recovered during search which could have been treated as incriminating material and would be a base for supporting the action u/s 153(C) - the addition on account of Cessation of liability u/sn 41(1) is illegal, in valid and not sustainable in the eye of law and If such course is permitted it would amount to reopening assessment without any new material - not permissible
Assessment u/s 153A - Addition u/s 41(1) - No material was recovered during search which could have been treated as incriminating material and would be a base for supporting the action u/s 153(C) - the addition on account of Cessation of liability u/sn 41(1) is illegal, in valid and not sustainable in the eye of law and If such course is permitted it would amount to reopening assessment without any new material - not permissible
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