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...
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
Additions based on Cash Expenditure - Disclosure were made by the appellant in IDS - The Tribunal ruled in favor of the appellant, holding that the entries did not warrant additional taxation. It noted that the expenses were from known sources and reconciled with existing books, thus not constituting unexplained expenditure under section 69C. Moreover, it accepted the appellant's claim regarding the disclosure under the Income Declaration Scheme, 2016, ruling that the expenses should not be treated as taxable income.
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