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...
Bogus share transactions involving abnormal price rise in penny stock shares - Assessee produced evidence of share purchase, existence in demat account - AO failed to rebut assessee's evidence, merely relied on circumstantial evidence - Ignorance of assessee about company's financials not crucial when transactions substantiated - Denial of exemption u/s 10(38) not justified - Addition u/s 68 deleted by CIT(A), upheld by ITAT - AO should have discharged onus after assessee's evidence.
Bogus share transactions involving abnormal price rise in penny stock shares - Assessee produced evidence of share purchase, existence in demat account - AO failed to rebut assessee's evidence, merely relied on circumstantial evidence - Ignorance of assessee about company's financials not crucial when transactions substantiated - Denial of exemption u/s 10(38) not justified - Addition u/s 68 deleted by CIT(A), upheld by ITAT - AO should have discharged onus after assessee's evidence.
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