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...
The ITAT Delhi ruled on an appeal regarding addition u/s 68 r.w.s. 115BBE for unexplained cash deposits during demonetization. The assessee explained that the deposits were from sale proceeds and past savings. The tribunal held that the AO did not find any discrepancies in the recorded purchases, sales, and stocks. Without evidence of non-genuine transactions or book rejection, assuming cash deposits based on higher turnover is unjustified. Therefore, the addition u/s 68 was deleted in favor of the assessee.
The ITAT Delhi ruled on an appeal regarding addition u/s 68 r.w.s. 115BBE for unexplained cash deposits during demonetization. The assessee explained that the deposits were from sale proceeds and past savings. The tribunal held that the AO did not find any discrepancies in the recorded purchases, sales, and stocks. Without evidence of non-genuine transactions or book rejection, assuming cash deposits based on higher turnover is unjustified. Therefore, the addition u/s 68 was deleted in favor of the assessee.
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