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...
Unaccounted investment u/s. 69C - The ITAT observed that the confusion arose because the assessee had treated the total booking amount (creditors) as closing work in progress, which the AO considered as unexplained investment. - The ITAT upheld the CIT(A)'s decision in deleting the addition, stating that the amount had already been offered for tax as gross profits.
Unaccounted investment u/s. 69C - The ITAT observed that the confusion arose because the assessee had treated the total booking amount (creditors) as closing work in progress, which the AO considered as unexplained investment. - The ITAT upheld the CIT(A)'s decision in deleting the addition, stating that the amount had already been offered for tax as gross profits.
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