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 gifts credited through banking channels were not taxable under section 69A absent corroborative evidence that they represented the assessee's own unaccounted money, and the addition was deleted. Cash received as on-money on property sales could not be taxed as unexplained money under section 69A; it had to be included in sale consideration and assessed under capital gains. Additions based only on uncorroborated Excel sheets for alleged construction were rejected. Major jewellery additions were partly explained by family and customary gifts, with the balance sustained, and telescoping was allowed against confirmed on-money receipts. Cash found during search was sustained, but telescoping was granted. The watch-related addition was deleted on proof of ownership and independent verification.
ITAT held that gifts credited through banking channels were not taxable under section 69A absent corroborative evidence that they represented the assessee's own unaccounted money, and the addition was deleted. Cash received as on-money on property sales could not be taxed as unexplained money under section 69A; it had to be included in sale consideration and assessed under capital gains. Additions based only on uncorroborated Excel sheets for alleged construction were rejected. Major jewellery additions were partly explained by family and customary gifts, with the balance sustained, and telescoping was allowed against confirmed on-money receipts. Cash found during search was sustained, but telescoping was granted. The watch-related addition was deleted on proof of ownership and independent verification.
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