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...
A search statement under section 132(4) was held insufficient by itself to sustain an addition under section 69A where it was promptly retracted and no corroborative incriminating material was found. The Tribunal noted that the assessee explained the circumstances of the statement, while the Assessing Officer produced no seized jewellery, cash deposits, bank material, documentary trail, or other independent evidence to support the alleged receipt or its application. Because the addition rested only on the retracted statement and the statutory burden was not discharged by independent corroboration, the appellate deletion of the addition was upheld.
A search statement under section 132(4) was held insufficient by itself to sustain an addition under section 69A where it was promptly retracted and no corroborative incriminating material was found. The Tribunal noted that the assessee explained the circumstances of the statement, while the Assessing Officer produced no seized jewellery, cash deposits, bank material, documentary trail, or other independent evidence to support the alleged receipt or its application. Because the addition rested only on the retracted statement and the statutory burden was not discharged by independent corroboration, the appellate deletion of the addition was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
