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 ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
The ITAT held that once the source of cash is taxed, it cannot be further taxed as unexplained cash expenditure in the hands of the assessee company. The assessee had furnished details regarding the source of cash expenditures which were accepted by the Interim Board for Settlement. The addition made u/s 69C for cash payments treated as unexplained expenditure by the Assessing Officer was deleted, as it would amount to double taxation, since the cash income was already offered to tax in the hands of the Director. The issue was decided in favour of the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
