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 - the Tribunal noted the extensive documentary evidence provided by the assessee to establish the legitimacy of the loan transactions. However, the AO failed to conduct proper investigations and relied solely on the report from the investigation wing. As the assessee had fulfilled its initial burden of proof, the Tribunal directed the deletion of the addition.
Addition u/s 68 - the Tribunal noted the extensive documentary evidence provided by the assessee to establish the legitimacy of the loan transactions. However, the AO failed to conduct proper investigations and relied solely on the report from the investigation wing. As the assessee had fulfilled its initial burden of proof, the Tribunal directed the deletion of the addition.
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