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 deposit - agricultural income or not - genuineness of receipt of cash on sale of Popular tree - Where the Revenue authorities disbelief the contents of the affidavit/confirmation, merely stating so and expressing such disbelief is not sufficient. The PAN number cannot be held to be proof of identity of the buyer. What was stopping the Revenue authorities in calling these persons whose name, address and Aadhar number are on record and recording their statement. - Additions deleted - AT
Unexplained cash deposit - agricultural income or not - genuineness of receipt of cash on sale of Popular tree - Where the Revenue authorities disbelief the contents of the affidavit/confirmation, merely stating so and expressing such disbelief is not sufficient. The PAN number cannot be held to be proof of identity of the buyer. What was stopping the Revenue authorities in calling these persons whose name, address and Aadhar number are on record and recording their statement. - Additions deleted - AT
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