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 68 - LTCG on sale of penny stock - considering the vortex of evidences, the assessee has successfully discharged the onus cast upon him by provisions of section 68 - discharge of onus u/s 68 is purely a question of fact and therefore the judicial decisions relied upon by the DR would do no good on the peculiar plethora of evidences in respect of the facts of the case in hand - no addition
Addition u/s 68 - LTCG on sale of penny stock - considering the vortex of evidences, the assessee has successfully discharged the onus cast upon him by provisions of section 68 - discharge of onus u/s 68 is purely a question of fact and therefore the judicial decisions relied upon by the DR would do no good on the peculiar plethora of evidences in respect of the facts of the case in hand - no addition
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