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 u/s 68 for director's loan ledger account was made by assessing officer (AO) considering transactions not matching previous year's financial statements. Assessee stated transactions pertained to prior assessment years. Tribunal held previous year's transactions cannot be considered income in current assessment year. Transactions related to FY 2012-13 and 2013-14, for which AO passed order u/s 143(3) on 29.01.2016 accepting closing balance of director's ledger account. AO cannot consider opening balance in current assessment year for making addition, relying on Sridev Enterprises judgment. Tribunal upheld CIT(Appeals) order deleting the addition, decided in favor of assessee.
Addition u/s 68 for director's loan ledger account was made by assessing officer (AO) considering transactions not matching previous year's financial statements. Assessee stated transactions pertained to prior assessment years. Tribunal held previous year's transactions cannot be considered income in current assessment year. Transactions related to FY 2012-13 and 2013-14, for which AO passed order u/s 143(3) on 29.01.2016 accepting closing balance of director's ledger account. AO cannot consider opening balance in current assessment year for making addition, relying on Sridev Enterprises judgment. Tribunal upheld CIT(Appeals) order deleting the addition, decided in favor of assessee.
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