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...
Jurisdiction of Single Member Bench of the Income Tax Appellate Tribunal - Monetary limit Rs.50 lakhs for hearing Appeal - In the present case, the assessee returned loss of (-) Rs.1,05 crores. AO made addition of Rs.1,06 crores and finally he determined the income of (+) Rs. 40 thousands - Only assessed income has to be looked into as stipulated in sub-section (3) of section 255 of the Act - AT
Jurisdiction of Single Member Bench of the Income Tax Appellate Tribunal - Monetary limit Rs.50 lakhs for hearing Appeal - In the present case, the assessee returned loss of (-) Rs.1,05 crores. AO made addition of Rs.1,06 crores and finally he determined the income of (+) Rs. 40 thousands - Only assessed income has to be looked into as stipulated in sub-section (3) of section 255 of the Act - AT
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