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...
Undisclosed income computation u/s 158-BB for search assessment cases. Assessing officer can consider materials found during search and other available information relatable to such evidence. Assessment based on search results and post-search enquiries. Assessee's arguments on lack of opportunity and non-consideration of employee affidavits rejected. Recovery of documents like correspondence, maps, stock positions, and truck loads from assessee's premises indicated undisclosed income from liquor business run through employees and benami companies despite licenses not in assessee's name. Cross-examination of persons whose statements were relied upon afforded to assessee. Rent agreement signed by assessee as contractor further supported findings. Tribunal upheld reassessment of undisclosed income earned through ghost/benami companies. Decided against assessee.
Undisclosed income computation u/s 158-BB for search assessment cases. Assessing officer can consider materials found during search and other available information relatable to such evidence. Assessment based on search results and post-search enquiries. Assessee's arguments on lack of opportunity and non-consideration of employee affidavits rejected. Recovery of documents like correspondence, maps, stock positions, and truck loads from assessee's premises indicated undisclosed income from liquor business run through employees and benami companies despite licenses not in assessee's name. Cross-examination of persons whose statements were relied upon afforded to assessee. Rent agreement signed by assessee as contractor further supported findings. Tribunal upheld reassessment of undisclosed income earned through ghost/benami companies. Decided against assessee.
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