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...
Additions u/s 56(2)(ix) - Mesne profit / liquidated damages - Amount remained with assessee after cancellation of the said sale in terms of the decree order of the Hon’ble jurisdictional Delhi High Court - the same was in the nature of mesne profit and beyond the provisions of section 56(2)(ix) - the said section is also not applicable as the twin conditions mentioned therein have not been met on the facts - AT
Additions u/s 56(2)(ix) - Mesne profit / liquidated damages - Amount remained with assessee after cancellation of the said sale in terms of the decree order of the Hon’ble jurisdictional Delhi High Court - the same was in the nature of mesne profit and beyond the provisions of section 56(2)(ix) - the said section is also not applicable as the twin conditions mentioned therein have not been met on the facts - AT
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