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...
Unexplained cash credit u/s 68 - hare capital against the said share application money was allowed in the earlier years - since the alleged sum was received during the year, AO was justified in asking the assessee to explain the source of said sum and since the assessee failed to file any documentary evidences and discharge the primary onus casted upon it and could not explain the source of said sum, provisions of Section 68 of the Act are attracted. - AT
Unexplained cash credit u/s 68 - hare capital against the said share application money was allowed in the earlier years - since the alleged sum was received during the year, AO was justified in asking the assessee to explain the source of said sum and since the assessee failed to file any documentary evidences and discharge the primary onus casted upon it and could not explain the source of said sum, provisions of Section 68 of the Act are attracted. - AT
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