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...
Addition restricted to parties mentioned in WhatsApp chat; estimation of gross profit (GP) at 8.60% on undisclosed sales of Rs. 26,58,600 and Rs. 6,11,043 confirmed; partial relief granted to assessee regarding undisclosed sales addition based on evidence; Appellate Tribunal's decision followed principles of natural justice and legal precedents.
Addition restricted to parties mentioned in WhatsApp chat; estimation of gross profit (GP) at 8.60% on undisclosed sales of Rs. 26,58,600 and Rs. 6,11,043 confirmed; partial relief granted to assessee regarding undisclosed sales addition based on evidence; Appellate Tribunal's decision followed principles of natural justice and legal precedents.
Note: It is a system-generated summary and is for quick reference only.