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 of on-money - Additions of on-money made u/s 68 on the basis of notings in loose sheets and data retrieved from the mobiles - when the A.O had in the assessment order mentioned the flat wise and year wise receipts of on-money thus, the same leaves no iota of doubt that the same were in the nature of “business receipts” which were inseparable from the assessee‟s business of a builder and developer. - AT
Addition of on-money - Additions of on-money made u/s 68 on the basis of notings in loose sheets and data retrieved from the mobiles - when the A.O had in the assessment order mentioned the flat wise and year wise receipts of on-money thus, the same leaves no iota of doubt that the same were in the nature of “business receipts” which were inseparable from the assessee‟s business of a builder and developer. - AT
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