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...
Addition towards unrecorded turnover - transaction of buy / sale in Paddy Basmati through National Spot Exhange Ltd. (NSEL) - The assessee kept raising a claim before the AO as well as the DRP that these transactions were recorded in the subsequent year. However, the assessee failed to substantiate his contention. - Additions confirmed - AT
Addition towards unrecorded turnover - transaction of buy / sale in Paddy Basmati through National Spot Exhange Ltd. (NSEL) - The assessee kept raising a claim before the AO as well as the DRP that these transactions were recorded in the subsequent year. However, the assessee failed to substantiate his contention. - Additions confirmed - AT
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