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...
Reverse burden under the 2002 Act applied once foundational facts showed the appellant's active connection with the entities and possession of loan and utilisation documents, so he had to displace the statutory presumption regarding proceeds of crime. The Tribunal held that he was not a mere nominal director and could not rely on liability principles from other statutes. It also required him to prove the lawful source of money in the frozen bank accounts under Section 8(1). His unsupported claim of income from a gym business and LIC commission failed, so retention of seized documents and devices, and continuance of the account freeze, were upheld.
Reverse burden under the 2002 Act applied once foundational facts showed the appellant's active connection with the entities and possession of loan and utilisation documents, so he had to displace the statutory presumption regarding proceeds of crime. The Tribunal held that he was not a mere nominal director and could not rely on liability principles from other statutes. It also required him to prove the lawful source of money in the frozen bank accounts under Section 8(1). His unsupported claim of income from a gym business and LIC commission failed, so retention of seized documents and devices, and continuance of the account freeze, were upheld.
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