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 cash credit - In fact, the loans are taken from close family members and friends. It is not a case of the AO that the assessee had taken loans from certain unknown people whose identity is in doubtful. AO is completely erred in making additions towards loan taken from above parties as unexplained credit u/s.68 - CIT(A) after considering relevant facts has rightly deleted the additions made by the AO. - AT
Unexplained cash credit - In fact, the loans are taken from close family members and friends. It is not a case of the AO that the assessee had taken loans from certain unknown people whose identity is in doubtful. AO is completely erred in making additions towards loan taken from above parties as unexplained credit u/s.68 - CIT(A) after considering relevant facts has rightly deleted the additions made by the AO. - AT
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