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 made being Specified Bank Notes deposited in the bank account of the assessee - whether the assessee had sufficient cash balance in its books for making the said deposits in the bank account? - Assessee has furnished the evidences and replies from the parties - AO had not brought any cogent evidence on record to disbelieve the details furnished by the parties and the assessee. - No additions - AT
Addition made being Specified Bank Notes deposited in the bank account of the assessee - whether the assessee had sufficient cash balance in its books for making the said deposits in the bank account? - Assessee has furnished the evidences and replies from the parties - AO had not brought any cogent evidence on record to disbelieve the details furnished by the parties and the assessee. - No additions - AT
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