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...
Income surrendered in survey action - undisclosed professional income - In fact, no such income has been found during the survey action. However, the assessee to keep his promise, has offered for taxation the surrendered additional professional income - Action of the AO in assessing the aforesaid surrendered income as income from unexplained sources u/s 69 cannot be held to be justified - To be taxed as professional income - AT
Income surrendered in survey action - undisclosed professional income - In fact, no such income has been found during the survey action. However, the assessee to keep his promise, has offered for taxation the surrendered additional professional income - Action of the AO in assessing the aforesaid surrendered income as income from unexplained sources u/s 69 cannot be held to be justified - To be taxed as professional income - AT
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