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...
Deposits of demonetized currencies - substantial increase in cash sales - The Assessing Officer highlighted instances of negative closing stock figures in the gold jewels register, indicating possible bogus sales. - The ITAT held that, it is the duty of the assessee to establish that there is sufficient stock available with the assessee and subsequently, sale was made. Thus, the preponderance of probability in favour of the assessee cannot be applied in this case.
Deposits of demonetized currencies - substantial increase in cash sales - The Assessing Officer highlighted instances of negative closing stock figures in the gold jewels register, indicating possible bogus sales. - The ITAT held that, it is the duty of the assessee to establish that there is sufficient stock available with the assessee and subsequently, sale was made. Thus, the preponderance of probability in favour of the assessee cannot be applied in this case.
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