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 - cash advance received from the customers - it cannot be expected from a seller to examine the creditworthiness of the buyers prior to selling any goods to any persons - the assessee cannot be blamed as the AO possesses all the details of customers and equipped with the full powers under the Act to call respective persons to examine the source of cash deposit by them to the assessee - no addition
Addition u/s 68 - cash advance received from the customers - it cannot be expected from a seller to examine the creditworthiness of the buyers prior to selling any goods to any persons - the assessee cannot be blamed as the AO possesses all the details of customers and equipped with the full powers under the Act to call respective persons to examine the source of cash deposit by them to the assessee - no addition
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