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 affirmed re-assessment notice for AY 2013-14 as valid under TOLA, finding no procedural objections by the assessee. On unexplained bank deposits, the tribunal determined a taxable profit margin of 8% rather than the assessee's proposed 3-7% range, lacking substantive evidence. The tribunal directed the Assessing Officer to separately compute business income and interest income, with TDS on interest to be brought to tax under income from other sources. The appeal was partly allowed, with the re-assessment proceedings upheld and a modified approach to taxing unexplained deposits implemented.
ITAT affirmed re-assessment notice for AY 2013-14 as valid under TOLA, finding no procedural objections by the assessee. On unexplained bank deposits, the tribunal determined a taxable profit margin of 8% rather than the assessee's proposed 3-7% range, lacking substantive evidence. The tribunal directed the Assessing Officer to separately compute business income and interest income, with TDS on interest to be brought to tax under income from other sources. The appeal was partly allowed, with the re-assessment proceedings upheld and a modified approach to taxing unexplained deposits implemented.
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