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...
Bogus LTCG - addition u/s 68 - exemption of LTCG u/s 10(38) - penny stock - neither the assessee nor his broker are named as illegitimate beneficiary to bogus LTCG in any of the alleged statements of the operators/brokers or reports/orders of SEBI or INV wing - AO has also failed to produce any material/evidence to dislodge or controvert the genuineness of the conclusive documentary evidences - no addition
Bogus LTCG - addition u/s 68 - exemption of LTCG u/s 10(38) - penny stock - neither the assessee nor his broker are named as illegitimate beneficiary to bogus LTCG in any of the alleged statements of the operators/brokers or reports/orders of SEBI or INV wing - AO has also failed to produce any material/evidence to dislodge or controvert the genuineness of the conclusive documentary evidences - no addition
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