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...
Unexplained income u/s 69A - undisclosed cash deposit in bank a/c - Department had also accepted the generation and availability of cash because of agricultural income for the year under consideration, therefore, there was no reason for ignoring the availability of cash with the assessee due to accumulative/past savings of the preceding years - Additions deleted - AT
Unexplained income u/s 69A - undisclosed cash deposit in bank a/c - Department had also accepted the generation and availability of cash because of agricultural income for the year under consideration, therefore, there was no reason for ignoring the availability of cash with the assessee due to accumulative/past savings of the preceding years - Additions deleted - AT
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