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...
Assessment u/s 153A - excess jewellery found in the residence of the assessee during the search - all the family members are income tax payee and are filing their respective income tax returns. Therefore, the addition so made in the hands of assessee needs to be reduced on this score. Hence, we direct the A.O. to make addition in respect of unexplained jewellery on pro-rata basis and restrict the additions in the hands of assessee of his share alone. - AT
Assessment u/s 153A - excess jewellery found in the residence of the assessee during the search - all the family members are income tax payee and are filing their respective income tax returns. Therefore, the addition so made in the hands of assessee needs to be reduced on this score. Hence, we direct the A.O. to make addition in respect of unexplained jewellery on pro-rata basis and restrict the additions in the hands of assessee of his share alone. - AT
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