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...
Rectification u/s 254 - Sale of land - land in question were sold by the assessee in the capacity of power of attorney holder and AO has assessed the income in the hand of the assessee who sold the land - earlier, the tribunal has deleted the addition - The summons issued by the AO if served upon the land owners then non appearance of the land owners would not discharge the AO from conducting further enquiry. Assessee cannot be blamed for non appearance of the land owners in response to the summons if any issued by the AO. - AT
Rectification u/s 254 - Sale of land - land in question were sold by the assessee in the capacity of power of attorney holder and AO has assessed the income in the hand of the assessee who sold the land - earlier, the tribunal has deleted the addition - The summons issued by the AO if served upon the land owners then non appearance of the land owners would not discharge the AO from conducting further enquiry. Assessee cannot be blamed for non appearance of the land owners in response to the summons if any issued by the AO. - AT
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