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...
Disallowance based on third party information about unexplained purchases was challenged. ITAT held that the additions were unsustainable as the disallowance was solely based on unverified third-party information gathered by the Department's Investigation Wing, without providing an opportunity for cross-examination to the assessee, who had prima facie substantiated the purchases through documentation like bills, confirmed accounts, and VAT registration of sellers. The purchases were found acceptable, and the consequent addition to income was directed to be deleted, favoring the assessee.
Disallowance based on third party information about unexplained purchases was challenged. ITAT held that the additions were unsustainable as the disallowance was solely based on unverified third-party information gathered by the Department's Investigation Wing, without providing an opportunity for cross-examination to the assessee, who had prima facie substantiated the purchases through documentation like bills, confirmed accounts, and VAT registration of sellers. The purchases were found acceptable, and the consequent addition to income was directed to be deleted, favoring the assessee.
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