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...
Income from undisclosed sources - addition of agricultural income - Assessment of agricultural income declared by the assessee for various assessment years was questioned by the Assessing Officer, leading to additions to total income as income from undisclosed sources. - The tribunal observed that on looking at the holding of the agricultural records of land holding, the agricultural produce mentioned there in and some of the bills of APMC produced before us clearly show that assessee is engaged in agricultural activities. - Additions made to the total income regarding the cash found in the locker and agricultural income were deemed unsustainable based on the evidence presented.
Income from undisclosed sources - addition of agricultural income - Assessment of agricultural income declared by the assessee for various assessment years was questioned by the Assessing Officer, leading to additions to total income as income from undisclosed sources. - The tribunal observed that on looking at the holding of the agricultural records of land holding, the agricultural produce mentioned there in and some of the bills of APMC produced before us clearly show that assessee is engaged in agricultural activities. - Additions made to the total income regarding the cash found in the locker and agricultural income were deemed unsustainable based on the evidence presented.
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