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...
The HC held that no unexplained money under s.69A arose in respect of the cash-in-hand carried from FY 2015-16 to FY 2016-17 and deposited during demonetisation. The court found an inextricable nexus between disclosed bank withdrawals, advances to third parties, interest receipts and subsequent return of funds evidenced in the assessee's balance sheet and the return of income filed and processed under s.143(1). Absence of a mandatory s.143(2) scrutiny notice rendered the return final for that assessment year, and the AO failed to demonstrate that the cash constituted unexplained income warranting invocation of s.69A. Decision: in favour of the assessee.
The HC held that no unexplained money under s.69A arose in respect of the cash-in-hand carried from FY 2015-16 to FY 2016-17 and deposited during demonetisation. The court found an inextricable nexus between disclosed bank withdrawals, advances to third parties, interest receipts and subsequent return of funds evidenced in the assessee's balance sheet and the return of income filed and processed under s.143(1). Absence of a mandatory s.143(2) scrutiny notice rendered the return final for that assessment year, and the AO failed to demonstrate that the cash constituted unexplained income warranting invocation of s.69A. Decision: in favour of the assessee.
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