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...
Trading in shares - allegation of transactions in penny stock scrip - unexplained income - Assessee has not paid the purchase cost nor received the entire sale consideration rather received the gain of Rs.1,655/- which cannot be considered as accommodation entry of gain of penny stock transaction. Therefore, direct the Assessing Officer to delete the entire addition. - AT
Trading in shares - allegation of transactions in penny stock scrip - unexplained income - Assessee has not paid the purchase cost nor received the entire sale consideration rather received the gain of Rs.1,655/- which cannot be considered as accommodation entry of gain of penny stock transaction. Therefore, direct the Assessing Officer to delete the entire addition. - AT
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