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 loan creditors - loan from farmers (having agriculture income) - AO has categorically mentioned that all of them are uneducated and having meagre agricultural land and some of them are having savings account with no balance - there is no satisfactory evidence about the credit worthiness of the creditors. We are of the view that the assessee failed to establish about the genuineness of the loan transactions except filing the affidavits. - Additions confirmed. - AT
Addition of loan creditors - loan from farmers (having agriculture income) - AO has categorically mentioned that all of them are uneducated and having meagre agricultural land and some of them are having savings account with no balance - there is no satisfactory evidence about the credit worthiness of the creditors. We are of the view that the assessee failed to establish about the genuineness of the loan transactions except filing the affidavits. - Additions confirmed. - AT
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