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...
Bogus loans u/s 68 - unsecured loans from the three loan creditors and interest on loans - reliance on third party statement - The ITAT upheld the CIT(A)'s order, stating that the assessee had discharged its burden by submitting the requisite information, and the onus lies on the AO to make enquiries. The AO failed to make further enquiries and relied on the statement recorded, which was retracted subsequently. - AT
Bogus loans u/s 68 - unsecured loans from the three loan creditors and interest on loans - reliance on third party statement - The ITAT upheld the CIT(A)'s order, stating that the assessee had discharged its burden by submitting the requisite information, and the onus lies on the AO to make enquiries. The AO failed to make further enquiries and relied on the statement recorded, which was retracted subsequently. - AT
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