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 Delhi High Court considered the addition u/s 68 and the evidentiary value of statements recorded u/s 132(4). The court emphasized that an assessment cannot be based solely on presumptions or statements without corroborating material. While statements are considered information, they must be supported by evidence found during a search for assessment. The court also discussed rectification u/s 292B, stating that jurisdictional defects cannot be cured under this section, rendering proceedings void. In this case, the Revenue failed to link seized material to the assessee group, leading to the assessment being set aside in favor of the assessee by the ITAT.
The Delhi High Court considered the addition u/s 68 and the evidentiary value of statements recorded u/s 132(4). The court emphasized that an assessment cannot be based solely on presumptions or statements without corroborating material. While statements are considered information, they must be supported by evidence found during a search for assessment. The court also discussed rectification u/s 292B, stating that jurisdictional defects cannot be cured under this section, rendering proceedings void. In this case, the Revenue failed to link seized material to the assessee group, leading to the assessment being set aside in favor of the assessee by the ITAT.
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