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 - unexplained cash credit - Assessee has discharged the primary onus to demonstrate fulfilment of primary ingredients of Sec.68 and it was incumbent upon revenue to dislodge the assessee’s claim by bringing on record, cogent material to establish that the assessee’s unaccounted money was routed in its books of account in the garb of unsecured loans
Addition u/s 68 - unexplained cash credit - Assessee has discharged the primary onus to demonstrate fulfilment of primary ingredients of Sec.68 and it was incumbent upon revenue to dislodge the assessee’s claim by bringing on record, cogent material to establish that the assessee’s unaccounted money was routed in its books of account in the garb of unsecured loans
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