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 considered a case involving denial of exemption u/s 10(38) for alleged bogus LTCG. The assessee invested in shares of a company deemed unreliable due to manipulation by brokers for undue benefits. The ITAT emphasized that profit magnitude does not establish the genuineness of an investee company. Despite the assessee's small profit, it was held that the transaction's genuineness cannot be determined solely by profit amount. The ITAT upheld the decision of the CIT (Appeals), dismissing the assessee's appeal based on the lack of error in the earlier order.
The ITAT considered a case involving denial of exemption u/s 10(38) for alleged bogus LTCG. The assessee invested in shares of a company deemed unreliable due to manipulation by brokers for undue benefits. The ITAT emphasized that profit magnitude does not establish the genuineness of an investee company. Despite the assessee's small profit, it was held that the transaction's genuineness cannot be determined solely by profit amount. The ITAT upheld the decision of the CIT (Appeals), dismissing the assessee's appeal based on the lack of error in the earlier order.
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