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, an Appellate Tribunal, addressed the validity of reopening assessment u/s 147 and addition u/s 68. The AO had sufficient material to believe the assessee introduced unaccounted income as bogus share capital, leading to income escapement. The notice u/s 147 was upheld as valid. The assessee failed to prove creditworthiness of share applicant or transaction genuineness. AO's addition u/s 68 was deemed justified, concluding the assessee channeled its own funds through investor companies. The assessee engaged in dubious activities, introducing unaccounted money through questionable transactions. The CIT(A)'s order was upheld, ruling against the assessee.
The ITAT, an Appellate Tribunal, addressed the validity of reopening assessment u/s 147 and addition u/s 68. The AO had sufficient material to believe the assessee introduced unaccounted income as bogus share capital, leading to income escapement. The notice u/s 147 was upheld as valid. The assessee failed to prove creditworthiness of share applicant or transaction genuineness. AO's addition u/s 68 was deemed justified, concluding the assessee channeled its own funds through investor companies. The assessee engaged in dubious activities, introducing unaccounted money through questionable transactions. The CIT(A)'s order was upheld, ruling against the assessee.
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