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...
Rule 27 permits a respondent to support the appellate order on an additional ground, and the alleged allotment breach could not justify disallowance in Assessment Year 2011-12 because the Revenue's material related to a later year. On the merits, the Revenue failed to prove breach of the beneficial housing-project deduction condition under section 80IB(10)(f): it relied mainly on a third-party statement, produced no reliable documentary evidence that the flats were really allotted to one person through nominees, and was denied effective cross-examination. The Tribunal treated the statutory condition as requiring cogent proof and sustained deletion of the disallowance; the Revenue's appeal for Assessment Year 2012-13 was rejected on the same reasoning.
Rule 27 permits a respondent to support the appellate order on an additional ground, and the alleged allotment breach could not justify disallowance in Assessment Year 2011-12 because the Revenue's material related to a later year. On the merits, the Revenue failed to prove breach of the beneficial housing-project deduction condition under section 80IB(10)(f): it relied mainly on a third-party statement, produced no reliable documentary evidence that the flats were really allotted to one person through nominees, and was denied effective cross-examination. The Tribunal treated the statutory condition as requiring cogent proof and sustained deletion of the disallowance; the Revenue's appeal for Assessment Year 2012-13 was rejected on the same reasoning.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
