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 investment u/s 69 - The tribunal closely examined the additions made under Section 69 related to unexplained investments in stock. The assessees argued that rough jottings or documents seized during raids were not conclusive evidence of unaccounted investments. Furthermore, they contended that previous voluntary disclosures or surrendered amounts during surveys should offset these additions.
Unexplained investment u/s 69 - The tribunal closely examined the additions made under Section 69 related to unexplained investments in stock. The assessees argued that rough jottings or documents seized during raids were not conclusive evidence of unaccounted investments. Furthermore, they contended that previous voluntary disclosures or surrendered amounts during surveys should offset these additions.
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