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 receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
A receipt under a collaboration agreement was treated as a business transaction, not an unexplained cash credit, because it moved through account-to-account banking channels and the payer's bank account showed no cash deposit before transfer. The assessee produced corporate records, PAN, returns, accounts and bank statements establishing identity, creditworthiness and genuineness; once that material was filed, the burden shifted to the department, which was not discharged. The Tribunal found the accommodation entry allegation unsupported by enquiry and based on suspicion, and deleted the section 68 addition. The reassessment ground was left open and not decided.
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