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 - Addition u/s 68 - bogus LTCG - Except the statement of the assessee u/s. 132(4) agreeing for the addition there is no seized incriminating material found in the premises of the assessee in the course of assessment proceedings. When there is no incriminating material found in the course of search in assessee’s premises the addition/disallowance cannot be made merely on the statements recorded in the course of the search proceedings. - AT
Assessment u/s 153A - Addition u/s 68 - bogus LTCG - Except the statement of the assessee u/s. 132(4) agreeing for the addition there is no seized incriminating material found in the premises of the assessee in the course of assessment proceedings. When there is no incriminating material found in the course of search in assessee’s premises the addition/disallowance cannot be made merely on the statements recorded in the course of the search proceedings. - AT
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