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 u/s 68 - unsecured loans - addition only on the basis of the information received from the Investigation Wing ignoring - the investing company has sufficient source to explain the investment made to the assessee company. From the above what is clear is that the assessee has discharged the onus cast upon her as per the provisions of section 68 of the Act by filing necessary evidences. Therefore, once it is proved that the assessee has discharged her onus, then the onus shift to the Assessing Officer to prove otherwise. - AT
Addition u/s 68 - unsecured loans - addition only on the basis of the information received from the Investigation Wing ignoring - the investing company has sufficient source to explain the investment made to the assessee company. From the above what is clear is that the assessee has discharged the onus cast upon her as per the provisions of section 68 of the Act by filing necessary evidences. Therefore, once it is proved that the assessee has discharged her onus, then the onus shift to the Assessing Officer to prove otherwise. - AT
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