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 on account of Unexplained paintings - Source of Investment made in the painting - the revenue had failed to place on record any ‘material’ which would irrefutably prove to the hilt that the investment in the aforesaid “two paintings” was made by the assessee during the year under consideration i.e A.Y 2008-09 - additions deleted.
Addition on account of Unexplained paintings - Source of Investment made in the painting - the revenue had failed to place on record any ‘material’ which would irrefutably prove to the hilt that the investment in the aforesaid “two paintings” was made by the assessee during the year under consideration i.e A.Y 2008-09 - additions deleted.
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