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...
Estimation of income - On Money - Unaccounted on money receipt from the real estate project - the assessing officer being investigator and adjudicator was under obligation to consider the entire seized material. The assessing officer has clearly recorded that the assessee receiving on money in cash and was incurring expenditure therefrom. No such fact was taken into consideration by assessing officer while estimating income from on money component. - CIT(A) rightly considered the on money for determination of income - AT
Estimation of income - On Money - Unaccounted on money receipt from the real estate project - the assessing officer being investigator and adjudicator was under obligation to consider the entire seized material. The assessing officer has clearly recorded that the assessee receiving on money in cash and was incurring expenditure therefrom. No such fact was taken into consideration by assessing officer while estimating income from on money component. - CIT(A) rightly considered the on money for determination of income - AT
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