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 expenditure u/s 69C - AO in the course of assessment had made enquiries from the vendors u/s 133(6) and since none of them responded to the same doubted genuineness of the transactions - the AO/DDIT had erred in sending notices / conducting field enquiry at their erstwhile site office at Bangalore, which had since been shut down after completion of the hotel project. - Additions made by the AO is unsustainable - AT
Unexplained expenditure u/s 69C - AO in the course of assessment had made enquiries from the vendors u/s 133(6) and since none of them responded to the same doubted genuineness of the transactions - the AO/DDIT had erred in sending notices / conducting field enquiry at their erstwhile site office at Bangalore, which had since been shut down after completion of the hotel project. - Additions made by the AO is unsustainable - AT
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