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...
Cash deposits during the demonetization period were recorded in the books of accounts, with the source maintained. The Assessing Officer invoked Section 69A and charged tax u/s 115BBE, treating the deposits as unexplained money. However, Section 69A is applicable when the assessee is the owner of money, bullion, jewelry, or valuable articles not recorded from any source. Since the cash deposits were recorded with the source maintained, invoking Section 69A was incorrect. Consequently, the addition made by the Assessing Officer is liable to be deleted, and the decision is in favor of the assessee.
Cash deposits during the demonetization period were recorded in the books of accounts, with the source maintained. The Assessing Officer invoked Section 69A and charged tax u/s 115BBE, treating the deposits as unexplained money. However, Section 69A is applicable when the assessee is the owner of money, bullion, jewelry, or valuable articles not recorded from any source. Since the cash deposits were recorded with the source maintained, invoking Section 69A was incorrect. Consequently, the addition made by the Assessing Officer is liable to be deleted, and the decision is in favor of the assessee.
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