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 68 - AO was not satisfied with the source of source aspect of the investors - The Tribunal agreed with the CIT(A)'s findings that the assessee company had discharged its onus under Section 68 by proving the nature and source of the share capital and share premium received from its directors, shareholders, and their relatives. - AT
Addition u/s 68 - AO was not satisfied with the source of source aspect of the investors - The Tribunal agreed with the CIT(A)'s findings that the assessee company had discharged its onus under Section 68 by proving the nature and source of the share capital and share premium received from its directors, shareholders, and their relatives. - AT
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