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 the share capital - Once the assessee has furnished the adequate evidence/material, the burden of the assessee is discharged in proving identity of shareholders, genuineness of transaction and creditworthiness of shareholder - in a case, wherein the shareholders have neither denied the investment nor any enquiry has been made by AO or adverse material was brought on record - addition not unsustainable in law
Addition of the share capital - Once the assessee has furnished the adequate evidence/material, the burden of the assessee is discharged in proving identity of shareholders, genuineness of transaction and creditworthiness of shareholder - in a case, wherein the shareholders have neither denied the investment nor any enquiry has been made by AO or adverse material was brought on record - addition not unsustainable in law
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