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...
Validity of reopening the assessment u/s 147 - Additions u/s 68 and u/s 69A - Cash deposits in assessee’s bank account - The ITAT observed that, the AO was satisfied that the assessee owned agricultural land and sold the same during this assessment year - The Tribunal concluded that the reopening of the assessment was valid, but the additions made by the AO and CIT(A) were not justified as the assessee had sufficiently explained the source of cash deposits. The appeal was partly allowed, and the additions made u/s 68 and 69A were set aside.
Validity of reopening the assessment u/s 147 - Additions u/s 68 and u/s 69A - Cash deposits in assessee’s bank account - The ITAT observed that, the AO was satisfied that the assessee owned agricultural land and sold the same during this assessment year - The Tribunal concluded that the reopening of the assessment was valid, but the additions made by the AO and CIT(A) were not justified as the assessee had sufficiently explained the source of cash deposits. The appeal was partly allowed, and the additions made u/s 68 and 69A were set aside.
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