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...
Bogus LTCG - Long-term capital gain exempt under Section 10(38) denied - Even if name of the appellant appeared in their statements, it could not have been used against the appellant until and unless the appellant was allowed an opportunity to cross examine the person whose statement was recorded during the course of survey/searches. - the material as received by the assessing officer behind the back of the appellant cannot be used against the appellant. - AT
Bogus LTCG - Long-term capital gain exempt under Section 10(38) denied - Even if name of the appellant appeared in their statements, it could not have been used against the appellant until and unless the appellant was allowed an opportunity to cross examine the person whose statement was recorded during the course of survey/searches. - the material as received by the assessing officer behind the back of the appellant cannot be used against the appellant. - AT
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