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 assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
The ITAT Delhi ruled on an assessment u/s 153A, focusing on additions u/s 68 and undisclosed sources based on the Assessee's bank statement. The Tribunal found no incriminating material during the search to support the additions. Citing precedents like Kabul Chawla and Meeta Gutgutia, the Tribunal deleted the addition. The Supreme Court in Abhisar Build well P. Ltd. held that additions without incriminating material from a search or requisition are invalid. The Assessee's appeal was allowed.
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