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 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
Addition u/s 68 - bogus LTCG - share capital and share premium were merely paper credit entries - receipt of accommodation entries in lieu of commission paid - The Tribunal found that the amounts received by BCPL were passed through various entities without actual business transactions, acting merely as accommodation entries. It was determined that these funds should not be treated as income of BCPL. Instead, only the commission income received for facilitating these transactions should be taxed.
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