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...
Unexplained investment - Tax value of certain assets received by it free of cost under Section 28(iv) - Therefore, the addition u/s. 69 of the Act cannot be sustained. - The entire value of assets has to be regarded as an addition made u/s. 28(1)(iv) of the Act, as was done by the AO - However the same would be eligible for deduction u/s 10A
Unexplained investment - Tax value of certain assets received by it free of cost under Section 28(iv) - Therefore, the addition u/s. 69 of the Act cannot be sustained. - The entire value of assets has to be regarded as an addition made u/s. 28(1)(iv) of the Act, as was done by the AO - However the same would be eligible for deduction u/s 10A
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