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...
Section 153C was upheld where the search warrant named only the searched persons, and the assessee's residence was covered in the course of that search, so the objection that assessment had to be framed under section 153A failed. Commission income from alleged hawala transactions was estimated at 0.3% of turnover because no evidence showed actual receipt and the higher rate was excessive. Cash found during search remained unexplained because the assessee produced no documentary proof to rebut the presumption arising from possession. A seized third-party voucher and loose papers were insufficient without independent corroboration, while the jewellery addition was deleted in light of customary family holdings and prior disclosures.
Section 153C was upheld where the search warrant named only the searched persons, and the assessee's residence was covered in the course of that search, so the objection that assessment had to be framed under section 153A failed. Commission income from alleged hawala transactions was estimated at 0.3% of turnover because no evidence showed actual receipt and the higher rate was excessive. Cash found during search remained unexplained because the assessee produced no documentary proof to rebut the presumption arising from possession. A seized third-party voucher and loose papers were insufficient without independent corroboration, while the jewellery addition was deleted in light of customary family holdings and prior disclosures.
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