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...
ITAT directs Assessing Officer (AO) to verify facts regarding loan/deposit investments after providing reasonable opportunity to assessee. Tribunal found no merit in additions under Section 68 for advances to Rainbow Tech, Arun Muchhala Engineering College, Arun Muchhala Research & Education Centre, and loans from Sai Shiva Developers, Mucchala Magic Land P. Ltd., and Arun Muchhala Co-owners. The tribunal noted that most disputed amounts were opening balances or partially repaid, and transactions were conducted through banking channels. Consequently, the tribunal deleted additions made under Section 68 and upheld the assessee's claim, remanding the matter back to AO for further verification with proper procedural fairness.
ITAT directs Assessing Officer (AO) to verify facts regarding loan/deposit investments after providing reasonable opportunity to assessee. Tribunal found no merit in additions under Section 68 for advances to Rainbow Tech, Arun Muchhala Engineering College, Arun Muchhala Research & Education Centre, and loans from Sai Shiva Developers, Mucchala Magic Land P. Ltd., and Arun Muchhala Co-owners. The tribunal noted that most disputed amounts were opening balances or partially repaid, and transactions were conducted through banking channels. Consequently, the tribunal deleted additions made under Section 68 and upheld the assessee's claim, remanding the matter back to AO for further verification with proper procedural fairness.
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