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...
AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions, ascertaining source of funds, verifying synchronized trades, summoning person who deposited cheques in assessee's account. Connivance of bankers, brokers, Demat agencies suspected in such scams. AO directed to make larger inquiry, summon relevant parties, determine real income and rightful assessee. Matter remanded to AO for fresh adjudication after due inquiry, providing fair opportunity to assessee. Appeal allowed.
AO failed to conduct proper inquiry regarding alleged bogus long term capital gain by not examining bankers, brokers, Demat agencies involved in transactions, ascertaining source of funds, verifying synchronized trades, summoning person who deposited cheques in assessee's account. Connivance of bankers, brokers, Demat agencies suspected in such scams. AO directed to make larger inquiry, summon relevant parties, determine real income and rightful assessee. Matter remanded to AO for fresh adjudication after due inquiry, providing fair opportunity to assessee. Appeal allowed.
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