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 u/s 68 - Each one of them has confirmed the MCX transaction and the confirmation account of each individual customers, transaction by transaction was submitted before the Assessing Officer. Thus, the assessee has established the three limbs of genuineness, creditworthiness and identity of the transactions as contemplated by various decisions of the High Court and Supreme Court envisaged u/s 68. - AT
Addition u/s 68 - Each one of them has confirmed the MCX transaction and the confirmation account of each individual customers, transaction by transaction was submitted before the Assessing Officer. Thus, the assessee has established the three limbs of genuineness, creditworthiness and identity of the transactions as contemplated by various decisions of the High Court and Supreme Court envisaged u/s 68. - AT
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