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 held that the assessee was not a shell company, since the record showed regular corporate existence and business activity; the returned business loss could not be rejected on that basis and was allowed to be carried forward. On section 68, the assessee discharged the initial burden by producing lender-wise confirmations, bank statements, ledger accounts, affidavits and returns, while the Revenue failed to make any independent rebuttal; the Tribunal also noted that proof of source of source was not required for unsecured loans for AY 2018-19. The entire addition under section 68 was deleted. Once the bank credits were accepted as genuine, the separate addition for unexplained investment based on the same funds was unsustainable and was also deleted.
ITAT held that the assessee was not a shell company, since the record showed regular corporate existence and business activity; the returned business loss could not be rejected on that basis and was allowed to be carried forward. On section 68, the assessee discharged the initial burden by producing lender-wise confirmations, bank statements, ledger accounts, affidavits and returns, while the Revenue failed to make any independent rebuttal; the Tribunal also noted that proof of source of source was not required for unsecured loans for AY 2018-19. The entire addition under section 68 was deleted. Once the bank credits were accepted as genuine, the separate addition for unexplained investment based on the same funds was unsustainable and was also deleted.
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