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 share transactions - Reliance on the statement of broker/entry operator - the denial of opportunity for cross-examination by the Assessing Officer was a failure of the principles of natural justice and thus the evidence used against the assessee was discarded. The Tribunal also recognized the assessee's documentation supporting the transactions, including ledger accounts, purchase and sale bills, and bank statements. - AT
Bogus share transactions - Reliance on the statement of broker/entry operator - the denial of opportunity for cross-examination by the Assessing Officer was a failure of the principles of natural justice and thus the evidence used against the assessee was discarded. The Tribunal also recognized the assessee's documentation supporting the transactions, including ledger accounts, purchase and sale bills, and bank statements. - AT
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