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...
Long Term Capital Gain - CIT(A) in holding that the land to the extent of 35% only is transferred whereas entire land has been transferred to the developers for which the assessee has received consideration of 65% of constructed area - we found that the revenue is raising a new issue at this stage. - now raising a ground for treating the transfer to the extent of 100% is neither justified on merits nor the same can be raised by the revenue at this stage. Accordingly, we dismiss this ground of appeal raised by the revenue - AT
Long Term Capital Gain - CIT(A) in holding that the land to the extent of 35% only is transferred whereas entire land has been transferred to the developers for which the assessee has received consideration of 65% of constructed area - we found that the revenue is raising a new issue at this stage. - now raising a ground for treating the transfer to the extent of 100% is neither justified on merits nor the same can be raised by the revenue at this stage. Accordingly, we dismiss this ground of appeal raised by the revenue - AT
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