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...
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
The High Court upheld the validity of reassessment u/s 153C and rejected the contention of reopening assessment u/s 147. The Assessing Officer relied on the material seized during the search for making additions in the assessees' hands. The Court affirmed the estimation of income on bogus purchases by the Tribunal at 6%, as it concurred with the reasoned decision of the fact-finding authorities. Consistent with similar cases involving accommodation entries, the 6% addition on estimated purchases maintained.
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