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 money deposited in bank account - stand of the assessee was that the cash deposited in his bank accounts are from the prospective buyers of vehicles/agricultural implements from where, he is working as Exchange Manager. Later on the cash was withdrawn and handed over to the employer i.e., Automobile Company - Accepting the contention, additions deleted - AT
Unexplained money deposited in bank account - stand of the assessee was that the cash deposited in his bank accounts are from the prospective buyers of vehicles/agricultural implements from where, he is working as Exchange Manager. Later on the cash was withdrawn and handed over to the employer i.e., Automobile Company - Accepting the contention, additions deleted - AT
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