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 - unexplained cash credits of share capital and security premium - assessee has no plausible explanation to explain the source of alleged sum of share capital and security premium. - it can be safely concluded that the assessee had unaccounted income, which has been routed in the books through bogus/accommodation entry in the form of share capital and security premium - AT
Addition u/s 68 - unexplained cash credits of share capital and security premium - assessee has no plausible explanation to explain the source of alleged sum of share capital and security premium. - it can be safely concluded that the assessee had unaccounted income, which has been routed in the books through bogus/accommodation entry in the form of share capital and security premium - AT
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