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 allowed the appeal, setting aside both AO and CIT(A) orders due to procedural irregularities. The appellate authority failed to adjudicate issues on merits as mandated under Section 250(6), and the AO made additions without substantive inquiry into expense claims. The tribunal found no specific defects in the assessee's expense documentation and determined that neither the assessment order nor the appellate order was legally sustainable. The matter was remanded to the AO for a de novo assessment, with the appeal allowed for statistical purposes, ensuring a comprehensive re-examination of the original expense claims and proportionate calculations.
ITAT allowed the appeal, setting aside both AO and CIT(A) orders due to procedural irregularities. The appellate authority failed to adjudicate issues on merits as mandated under Section 250(6), and the AO made additions without substantive inquiry into expense claims. The tribunal found no specific defects in the assessee's expense documentation and determined that neither the assessment order nor the appellate order was legally sustainable. The matter was remanded to the AO for a de novo assessment, with the appeal allowed for statistical purposes, ensuring a comprehensive re-examination of the original expense claims and proportionate calculations.
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