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...
Unexplained cash credit u/s 68 r.w.s 115BBE - inflated sales pursuant to demonetization - Unaccounted Stock Due to Valuation Differences - The Tribunal held that the addition made by the Revenue on account of undisclosed income from the sale of diamonds was unjustified, as the transactions were recorded in the books and formed part of the assessee's regular business operations. - The Tribunal dismissed the addition made on account of the alleged unaccounted stock, recognizing the discrepancy as a result of a typographical error in the tax audit report.
Unexplained cash credit u/s 68 r.w.s 115BBE - inflated sales pursuant to demonetization - Unaccounted Stock Due to Valuation Differences - The Tribunal held that the addition made by the Revenue on account of undisclosed income from the sale of diamonds was unjustified, as the transactions were recorded in the books and formed part of the assessee's regular business operations. - The Tribunal dismissed the addition made on account of the alleged unaccounted stock, recognizing the discrepancy as a result of a typographical error in the tax audit report.
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