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 dismissed Revenue's appeal regarding unexplained expenditure under section 69C. The Tribunal found that the Assessing Officer (AO) erroneously made additions based on unsubstantiated handwritten loose documents without meaningful inquiry. The seized documents lacked corroboration, contained arithmetic mistakes, and did not align with shareholders' records. The Tribunal emphasized that loose sheets are inadmissible without additional evidence under the Indian Evidence Act. The Fair Market Value calculation was deemed appropriate, considering factors like intellectual capital and future profit potential. Ultimately, the appeal was rejected, with the Tribunal concluding that the additions made during the search action were not sacrosanct or conclusive.
ITAT dismissed Revenue's appeal regarding unexplained expenditure under section 69C. The Tribunal found that the Assessing Officer (AO) erroneously made additions based on unsubstantiated handwritten loose documents without meaningful inquiry. The seized documents lacked corroboration, contained arithmetic mistakes, and did not align with shareholders' records. The Tribunal emphasized that loose sheets are inadmissible without additional evidence under the Indian Evidence Act. The Fair Market Value calculation was deemed appropriate, considering factors like intellectual capital and future profit potential. Ultimately, the appeal was rejected, with the Tribunal concluding that the additions made during the search action were not sacrosanct or conclusive.
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