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...
Disallowance u/s 54F - Investment of Sale consideration for claiming exemption on LTCG - Advance was given for purchase of new residential property but the transaction was not materialized due to litigation - purchase of new residential property thereafter after getting refund of advance - failure to deposit into the capital gain account with the authorized banks - Since the assessee has fulfilled the substantive condition of Section 54F(1) of the Act by way of utilizing the sale consideration from sale of the capital asset (other than residential house) within two years of sale of original capital asset, assessee is eligible for deduction u/s 54F(1) - AT
Disallowance u/s 54F - Investment of Sale consideration for claiming exemption on LTCG - Advance was given for purchase of new residential property but the transaction was not materialized due to litigation - purchase of new residential property thereafter after getting refund of advance - failure to deposit into the capital gain account with the authorized banks - Since the assessee has fulfilled the substantive condition of Section 54F(1) of the Act by way of utilizing the sale consideration from sale of the capital asset (other than residential house) within two years of sale of original capital asset, assessee is eligible for deduction u/s 54F(1) - AT
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