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...
Enhancement of Capital Gain - Initially the value was taken as determined by the Sub-Registrar - Later, on objection raised by asessee, matter was referred to DVO - Application of section 50C, since the land is in Dark Zone - DVO has taken excessive rate without considering the average rate per Bigha which is more than double of prevailing Market rate - In addition to cost of boundary wall as taken by the DVO also considered for cost of acquisition - Relief granted to the assessee - AT
Enhancement of Capital Gain - Initially the value was taken as determined by the Sub-Registrar - Later, on objection raised by asessee, matter was referred to DVO - Application of section 50C, since the land is in Dark Zone - DVO has taken excessive rate without considering the average rate per Bigha which is more than double of prevailing Market rate - In addition to cost of boundary wall as taken by the DVO also considered for cost of acquisition - Relief granted to the assessee - AT
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