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 Bangalore addressed unexplained cash deposits u/s 69A, focusing on the credibility of earlier withdrawals as a source for redeposits. The Tribunal examined fund flow and cash flow statements, presuming cash availability for redeposit. The assessee deposited sums during demonetization, providing bank account details, rent agreements, and rental income confirmation. The assessee explained using earlier withdrawals and tenant payments for redeposits, supported by the case of S.R. Venkataratnam. The Tribunal ruled in favor of the assessee, allowing credit for cash withdrawals and rental income towards bank deposits, deleting the addition for unexplained cash deposits during demonetization.
The ITAT Bangalore addressed unexplained cash deposits u/s 69A, focusing on the credibility of earlier withdrawals as a source for redeposits. The Tribunal examined fund flow and cash flow statements, presuming cash availability for redeposit. The assessee deposited sums during demonetization, providing bank account details, rent agreements, and rental income confirmation. The assessee explained using earlier withdrawals and tenant payments for redeposits, supported by the case of S.R. Venkataratnam. The Tribunal ruled in favor of the assessee, allowing credit for cash withdrawals and rental income towards bank deposits, deleting the addition for unexplained cash deposits during demonetization.
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