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 under section 68 being share capital received and addition under section 69C on account of commission - some of Directors did not appear in the case of assessee - the assessee-company has been able to prove the identity of the Investor, its creditworthiness and genuineness of the transaction in the matter. - Additions deleted - AT
Addition under section 68 being share capital received and addition under section 69C on account of commission - some of Directors did not appear in the case of assessee - the assessee-company has been able to prove the identity of the Investor, its creditworthiness and genuineness of the transaction in the matter. - Additions deleted - AT
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