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...
Addition u/s 69C - bogus purchases of diamonds - The decision emphasizes the principle that where the genuineness of purchases is in question, but corresponding sales are not disputed, only the profit element embedded in the transactions should be brought to tax. The Tribunal's ruling aligns with the principle that in cases of alleged bogus purchases, if sales are unaffected, the focus should be on taxing the profit margin rather than disallowing entire purchases. - AT
Addition u/s 69C - bogus purchases of diamonds - The decision emphasizes the principle that where the genuineness of purchases is in question, but corresponding sales are not disputed, only the profit element embedded in the transactions should be brought to tax. The Tribunal's ruling aligns with the principle that in cases of alleged bogus purchases, if sales are unaffected, the focus should be on taxing the profit margin rather than disallowing entire purchases. - AT
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