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...
Undisclosed income (from equity transactions) - unexplained investment (by way of cash deposit) u/s 69 r/w Section 115 BBE - huge amount of money was transacted using the Firm's PAN number - Assessment against deceased partner - AO ought to have compared the income that was proposed to be added pursuant to notice dated 31.03.2022 with the income declared by the petitioner's deceased husband (late) while finalizing the assessment. There is no comparison. - Matter restored back - HC
Undisclosed income (from equity transactions) - unexplained investment (by way of cash deposit) u/s 69 r/w Section 115 BBE - huge amount of money was transacted using the Firm's PAN number - Assessment against deceased partner - AO ought to have compared the income that was proposed to be added pursuant to notice dated 31.03.2022 with the income declared by the petitioner's deceased husband (late) while finalizing the assessment. There is no comparison. - Matter restored back - HC
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