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...
Additions towards difference in interest income between interest as per Form 26AS and interest income shown in the Return of Income - Since the alleged accommodation loan was treated as bogus and assessing officer made estimation addition, hence addition on account of difference in interest income, is tantamount to double addition, hence the same is hereby deleted. - AT
Additions towards difference in interest income between interest as per Form 26AS and interest income shown in the Return of Income - Since the alleged accommodation loan was treated as bogus and assessing officer made estimation addition, hence addition on account of difference in interest income, is tantamount to double addition, hence the same is hereby deleted. - AT
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