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...
ITAT confirmed the deletion of additions by the CIT(A) - Finding of the tribunal, directly and substantially interferes in the interest of revenue and the finding are not based on the evidence brought on record by the assessing officer and the order of the Tribunal suffers from material irregularities without any independent reasons, it has glossed over the relevant facts, which were brought on record by the assessing officer and therefore, the impugned orders are perverse and undoubtedly, perversity can be taken up in an appeal under Section 260A of the Act. - HC
ITAT confirmed the deletion of additions by the CIT(A) - Finding of the tribunal, directly and substantially interferes in the interest of revenue and the finding are not based on the evidence brought on record by the assessing officer and the order of the Tribunal suffers from material irregularities without any independent reasons, it has glossed over the relevant facts, which were brought on record by the assessing officer and therefore, the impugned orders are perverse and undoubtedly, perversity can be taken up in an appeal under Section 260A of the Act. - HC
Note: It is a system-generated summary and is for quick reference only.