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 share capital receipt - Mere paperwork by the assessee does not take the authorities anywhere, when the learned AO suspected the real existence of the entities that applied and paid for share application and share premium and insisted that a higher degree of proof is required in that respect. - Order of the CIT(A) deleting the additions, set aside - AT
Addition u/s 68 - Unexplained share capital receipt - Mere paperwork by the assessee does not take the authorities anywhere, when the learned AO suspected the real existence of the entities that applied and paid for share application and share premium and insisted that a higher degree of proof is required in that respect. - Order of the CIT(A) deleting the additions, set aside - AT
Note: It is a system-generated summary and is for quick reference only.