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 held that an Urban Cooperative Bank's acceptance of cash in the form of Specified Bank Notes (SBNs) cannot be considered unexplained income u/s 68 due to RBI Circular restricting exchange to District Cooperative Central Banks only. The grounds raised by the assessee were allowed.
The ITAT held that an Urban Cooperative Bank's acceptance of cash in the form of Specified Bank Notes (SBNs) cannot be considered unexplained income u/s 68 due to RBI Circular restricting exchange to District Cooperative Central Banks only. The grounds raised by the assessee were allowed.
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