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...
Levy of Tax u/s 115BBE @60% - Income surrendered during the course of search - the provisions of Section 69 were not applicable as the business transactions were recorded in the books of account and the assessee either earned commission or profit on all those Real Estate transactions. - A.O. is directed to tax the entire surrendered income at the normal rate of tax. - AT
Levy of Tax u/s 115BBE @60% - Income surrendered during the course of search - the provisions of Section 69 were not applicable as the business transactions were recorded in the books of account and the assessee either earned commission or profit on all those Real Estate transactions. - A.O. is directed to tax the entire surrendered income at the normal rate of tax. - AT
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