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...
Non-genuine purchases u/s 69C - Sales tax department had provided evidence of the fact that these parties did not undertake the sale of any material but only provided bills at a commission - ITAT upholding the orders of the CIT(A) deleting the addition - this is not a fit case for consideration in appeal as the substantial questions of law proposed by the revenue would not arise. - HC
Non-genuine purchases u/s 69C - Sales tax department had provided evidence of the fact that these parties did not undertake the sale of any material but only provided bills at a commission - ITAT upholding the orders of the CIT(A) deleting the addition - this is not a fit case for consideration in appeal as the substantial questions of law proposed by the revenue would not arise. - HC
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