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 on account of excess stock - discrepancies in stock records, unaccounted sales - we are satisfied with the documentary evidence that the alleged stock of cotton bales were part of book stock and they were issued out of stock on 24.1.2012 and were sold through the invoices issued on 25.1.2012. Physical stock was taken by the revenue authorities on the date of survey on 24.1.2002 - Addition deleted.- AT
Addition on account of excess stock - discrepancies in stock records, unaccounted sales - we are satisfied with the documentary evidence that the alleged stock of cotton bales were part of book stock and they were issued out of stock on 24.1.2012 and were sold through the invoices issued on 25.1.2012. Physical stock was taken by the revenue authorities on the date of survey on 24.1.2002 - Addition deleted.- AT
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