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 investment in closing stock u/s. 69 - difference in the quantity of closing stock as per software - once the said software was stopped being used after the search due to its shortcomings and was also removed from all the systems, it was not possible for the assessee to give required details of stock as per Jilaba software - we found that the ld. CIT(A) has passed a well-reasoned and speaking order discussing all the facts and circumstances of the case - CIT(A) rightly deleted the additions - AT
Unexplained investment in closing stock u/s. 69 - difference in the quantity of closing stock as per software - once the said software was stopped being used after the search due to its shortcomings and was also removed from all the systems, it was not possible for the assessee to give required details of stock as per Jilaba software - we found that the ld. CIT(A) has passed a well-reasoned and speaking order discussing all the facts and circumstances of the case - CIT(A) rightly deleted the additions - AT
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