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...
Where an assessee disputes stamp duty value under Section 43CA and the matter is referred to the DVO, the DVO valuation substitutes the stamp duty value for testing the safe harbour tolerance band. Applying that principle, the Tribunal found that in each impugned transaction the difference between the agreement value and the DVO valuation was below the prescribed 10% margin. As the variation remained within the permissible tolerance, the deeming fiction under Section 43CA could not be invoked and the addition could not survive; the addition was deleted.
Where an assessee disputes stamp duty value under Section 43CA and the matter is referred to the DVO, the DVO valuation substitutes the stamp duty value for testing the safe harbour tolerance band. Applying that principle, the Tribunal found that in each impugned transaction the difference between the agreement value and the DVO valuation was below the prescribed 10% margin. As the variation remained within the permissible tolerance, the deeming fiction under Section 43CA could not be invoked and the addition could not survive; the addition was deleted.
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