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...
Appellate Authority affirmed impugned order without evidence...
Appellate authority's inconsistent approach in accepting/rejecting contentions sans evidence rejected. Order quashed, remanded for judicial consideration.
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Appellate Authority affirmed impugned order without evidence regarding petitioner's intention to evade tax. Inconsistent approach rejecting petitioner's contention for lack of evidence while accepting department's contention despite absence of evidence. Appellate Authority must act judicially, adopting same approach towards assessee and department. Order quashed, petition allowed by way of remand.
Appellate Authority affirmed impugned order without evidence regarding petitioner's intention to evade tax. Inconsistent approach rejecting petitioner's contention for lack of evidence while accepting department's contention despite absence of evidence. Appellate Authority must act judicially, adopting same approach towards assessee and department. Order quashed, petition allowed by way of remand.
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