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...
Adopting the commission income at 0.5% - Unexplained bank deposits - assessee could not rebut the fact that the assessee himself has stated of having received commission in cash @ 0.5% out of which 0.3% was paid as bank charges. We find that the CIT(Appeal) on the basis of this statement has adopted the commission income but he has allowed the expenses on the actual basis - statement cannot be used in part. It is to be read as a whole. Therefore, considering the statement of the assessee we hereby direct the Assessing Officer to adopt 0.20% as the net commission income of the assessee. - AT
Adopting the commission income at 0.5% - Unexplained bank deposits - assessee could not rebut the fact that the assessee himself has stated of having received commission in cash @ 0.5% out of which 0.3% was paid as bank charges. We find that the CIT(Appeal) on the basis of this statement has adopted the commission income but he has allowed the expenses on the actual basis - statement cannot be used in part. It is to be read as a whole. Therefore, considering the statement of the assessee we hereby direct the Assessing Officer to adopt 0.20% as the net commission income of the assessee. - AT
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