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 - unexplained cash credit - The tribunal noted that the transactions were conducted through banking channels, and the assessee had provided all necessary documentation, including the identity and financial status of the investor company. The decision emphasized that suspicion, however strong, cannot substitute for proof and that the genuineness of the transactions was adequately established by the assessee.
Addition u/s 68 - unexplained cash credit - The tribunal noted that the transactions were conducted through banking channels, and the assessee had provided all necessary documentation, including the identity and financial status of the investor company. The decision emphasized that suspicion, however strong, cannot substitute for proof and that the genuineness of the transactions was adequately established by the assessee.
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