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...
Income-tax search material can be relied on in benami proceedings absent any statutory bar, and the fact that the material originated in tax proceedings does not require a separate independent enquiry as a precondition to benami adjudication. The Tribunal held that routed accommodation entries, supported by connected statements and corroborating electronic records, established a benami transaction; retraction alone did not displace those statements where no satisfactory basis for retraction was shown. It also held that income-tax assessment and benami adjudication operate in distinct fields, so tax treatment of undisclosed income does not preclude a parallel benami finding. The provisional attachment was therefore sustained and the appeals were dismissed.
Income-tax search material can be relied on in benami proceedings absent any statutory bar, and the fact that the material originated in tax proceedings does not require a separate independent enquiry as a precondition to benami adjudication. The Tribunal held that routed accommodation entries, supported by connected statements and corroborating electronic records, established a benami transaction; retraction alone did not displace those statements where no satisfactory basis for retraction was shown. It also held that income-tax assessment and benami adjudication operate in distinct fields, so tax treatment of undisclosed income does not preclude a parallel benami finding. The provisional attachment was therefore sustained and the appeals were dismissed.
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