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...
HC held that additions to income under block assessment can be made based on statements recorded u/s 132(4) and seized materials. The appellant's argument attributing income to deceased father was rejected due to lack of supporting evidence. The court found the statement reliable as the appellant did not retract it and failed to respond to notice u/s 158BC. Seized materials and assessee's own statement substantiated the income additions. Relying on precedent, the court affirmed that where inferences about undisclosed income are strong and based on search materials and statements, such additions are permissible. The order was ultimately decided in favor of the revenue.
HC held that additions to income under block assessment can be made based on statements recorded u/s 132(4) and seized materials. The appellant's argument attributing income to deceased father was rejected due to lack of supporting evidence. The court found the statement reliable as the appellant did not retract it and failed to respond to notice u/s 158BC. Seized materials and assessee's own statement substantiated the income additions. Relying on precedent, the court affirmed that where inferences about undisclosed income are strong and based on search materials and statements, such additions are permissible. The order was ultimately decided in favor of the revenue.
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