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 ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
The ITAT upheld the AO's disallowance under section 292C, finding no contemporaneous claim of expenses or liabilities during the survey and dismissing the assessee's Ground No.2; the addition stands. The Tribunal directed recalculation of allowable partners' remuneration under section 40(b) (Explanation 3) by computing book profit after adding back confirmed additions of Rs. 62,28,947 and adhoc disallowances of Rs. 15,620, and ordered the AO to allow the remuneration claim accordingly. The Bench held that income declared during survey is taxable as business income under section 28, hence section 115BBE, and provisions applicable to deemed unexplained credits are not attracted.
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