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 r.w. section 115BBE - unexplained cash deposits in the bank account - The tribunal finds that the AO did not provide a satisfactory explanation for rejecting the source of cash deposits - The ITAT held that the authorities erred in treating the cash deposits as unexplained income without any evidence to question the genuineness of the sales or the source of funds. The assessee's appeal was allowed, and the addition made by the authorities was deleted.
Addition u/s 68 r.w. section 115BBE - unexplained cash deposits in the bank account - The tribunal finds that the AO did not provide a satisfactory explanation for rejecting the source of cash deposits - The ITAT held that the authorities erred in treating the cash deposits as unexplained income without any evidence to question the genuineness of the sales or the source of funds. The assessee's appeal was allowed, and the addition made by the authorities was deleted.
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