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 of income declared by assessee under Voluntary Disclosure of Income Scheme, 1997 (VDIS, 1997’) - The Tribunal allowed the assessee's appeal and deleted the addition made by the ITD. The Tribunal noted that the assessee provided evidence to support their claim that the investments and expenditures related to previous years, and the ITD did not establish that they occurred in 1997-98.
Addition of income declared by assessee under Voluntary Disclosure of Income Scheme, 1997 (VDIS, 1997’) - The Tribunal allowed the assessee's appeal and deleted the addition made by the ITD. The Tribunal noted that the assessee provided evidence to support their claim that the investments and expenditures related to previous years, and the ITD did not establish that they occurred in 1997-98.
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