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...
Reopening of assessment u/s 147 - Unexplained cash deposits - in the order-sheet, the assessee’s representative has accepted that the bank accounts wherein cash deposited, which are nothing but belongs to the assessee only. Therefore, the contention of the assessee that the bank account are not belongs to him is not proved with proper evidence. - Additions confirmed - AT
Reopening of assessment u/s 147 - Unexplained cash deposits - in the order-sheet, the assessee’s representative has accepted that the bank accounts wherein cash deposited, which are nothing but belongs to the assessee only. Therefore, the contention of the assessee that the bank account are not belongs to him is not proved with proper evidence. - Additions confirmed - AT
Note: It is a system-generated summary and is for quick reference only.