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 69 - unexplained investment made in purchase of land - no asset came into existence in the name of the assessee, which requires to be shown in the books of accounts. The ld.AO has simply assumed certain facts, and assumed existence of unexplained asset which requires to be added u/s 69 - Additions were rightly deleted.
Addition u/s 69 - unexplained investment made in purchase of land - no asset came into existence in the name of the assessee, which requires to be shown in the books of accounts. The ld.AO has simply assumed certain facts, and assumed existence of unexplained asset which requires to be added u/s 69 - Additions were rightly deleted.
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