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...
Rectification u/s 154 - Substitution of addition u/s 269SS with 69A - unsecured loans - assessee engaged in banking business - Enhancement of tax liability u/s 115BBE - The ITAT Ahmedabad, after hearing both parties, found discrepancies in the application of sections 269SS and 69A to the cooperative bank's case. The rectification order was deemed a typographical error without proper verification. The ITAT directed the AO to reexamine the applicability of section 69A, ensuring proper evidence and hearing, and allowed the appeals partly for statistical purposes.
Rectification u/s 154 - Substitution of addition u/s 269SS with 69A - unsecured loans - assessee engaged in banking business - Enhancement of tax liability u/s 115BBE - The ITAT Ahmedabad, after hearing both parties, found discrepancies in the application of sections 269SS and 69A to the cooperative bank's case. The rectification order was deemed a typographical error without proper verification. The ITAT directed the AO to reexamine the applicability of section 69A, ensuring proper evidence and hearing, and allowed the appeals partly for statistical purposes.
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