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...
Bogus LTCG - addition u/s 68 - income arising from sale of shares - Facts as emanating from material on record demonstrate that the conduct of the Assessee in the present case does not fit into the ‘modus operandi’ as stated in the report of Investigation Wing, Kolkata. - addition made by AO u/s 68 of the Act cannot be sustained. - AT
Bogus LTCG - addition u/s 68 - income arising from sale of shares - Facts as emanating from material on record demonstrate that the conduct of the Assessee in the present case does not fit into the ‘modus operandi’ as stated in the report of Investigation Wing, Kolkata. - addition made by AO u/s 68 of the Act cannot be sustained. - AT
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