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 of agricultural income as unexplained income - No agriculture activities can be said to be done. Further, in the form No. 7/12, there is no details of farming being done by the assessee and the nature of the crops, and the quantification of the land, has not been mentioned. - Additions confirmed - However, AO directed to make a disallowance to the extent of 25% of the expenditure on account of earning of agriculture income and pass an order accordingly - AT
Addition of agricultural income as unexplained income - No agriculture activities can be said to be done. Further, in the form No. 7/12, there is no details of farming being done by the assessee and the nature of the crops, and the quantification of the land, has not been mentioned. - Additions confirmed - However, AO directed to make a disallowance to the extent of 25% of the expenditure on account of earning of agriculture income and pass an order accordingly - AT
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