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...
Reassessment based only on a Suspicious Transaction Report and an investigation wing report for verifying transactions with suppliers was held bad in law because suspicion-based material did not amount to information suggesting escapement of income. On the merits, the assessee supported the purchases with invoices, ledger accounts, confirmations, bank statements, GST records and other documents, and the Revenue failed to rebut that evidence. The Tribunal held that suspicion cannot replace proof, rejected gross profit estimation on a mere possibility of accommodation entries, and directed deletion of the entire addition. The Revenue's appeal was dismissed and the assessee's cross-objection was allowed.
Reassessment based only on a Suspicious Transaction Report and an investigation wing report for verifying transactions with suppliers was held bad in law because suspicion-based material did not amount to information suggesting escapement of income. On the merits, the assessee supported the purchases with invoices, ledger accounts, confirmations, bank statements, GST records and other documents, and the Revenue failed to rebut that evidence. The Tribunal held that suspicion cannot replace proof, rejected gross profit estimation on a mere possibility of accommodation entries, and directed deletion of the entire addition. The Revenue's appeal was dismissed and the assessee's cross-objection was allowed.
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