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 us 68 - CIT-A deleted the addition - Considering the discrepancy shown by the Ld. CIT(A), we are of the opinion that the order passed by the Ld. CIT(A) in not in accordance with the principles of natural justice by not granting an opportunity to the Assessing Officer for explaining whether there was any typographical error in the balance sheet - Matter restored back - AT
Addition us 68 - CIT-A deleted the addition - Considering the discrepancy shown by the Ld. CIT(A), we are of the opinion that the order passed by the Ld. CIT(A) in not in accordance with the principles of natural justice by not granting an opportunity to the Assessing Officer for explaining whether there was any typographical error in the balance sheet - Matter restored back - AT
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