Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
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Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The ITAT upheld the deletion of additions related to unexplained sundry creditors, finding no infirmity in the CIT(A)'s acceptance of additional evidence, including an agency agreement justifying adjustments between parties. The AO's jurisdiction to scrutinize sundry creditors was affirmed but the related disallowance under section 14A was already deleted by CIT(A) and not challenged, rendering that issue final. The assessee's challenge to interest disallowance under limited scrutiny was dismissed. However, regarding disallowance under section 36(1)(iii), the ITAT reversed CIT(A)'s directive for recomputation, holding that the assessee's demonstration of sufficient interest-free funds to cover advances negated any disallowance. Consequently, the assessee's ground on this point was allowed, resulting in the overall dismissal of the revenue's appeal and partial allowance of the assessee's cross-objection.
The ITAT upheld the deletion of additions related to unexplained sundry creditors, finding no infirmity in the CIT(A)'s acceptance of additional evidence, including an agency agreement justifying adjustments between parties. The AO's jurisdiction to scrutinize sundry creditors was affirmed but the related disallowance under section 14A was already deleted by CIT(A) and not challenged, rendering that issue final. The assessee's challenge to interest disallowance under limited scrutiny was dismissed. However, regarding disallowance under section 36(1)(iii), the ITAT reversed CIT(A)'s directive for recomputation, holding that the assessee's demonstration of sufficient interest-free funds to cover advances negated any disallowance. Consequently, the assessee's ground on this point was allowed, resulting in the overall dismissal of the revenue's appeal and partial allowance of the assessee's cross-objection.
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