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...
Capital gain - Additions made u/s 50C - by no stretch of imagination, without making any sport physical verification, two piece of land can be compared to work out the fair market value. The assessing officer has simply borrowed the finding of CIT(A)-IV, Surat, without seeing its relevance or reference and applied the fair market value on the assessee’s land. No addition under section 50C can be made in absence of any evidence. - AT
Capital gain - Additions made u/s 50C - by no stretch of imagination, without making any sport physical verification, two piece of land can be compared to work out the fair market value. The assessing officer has simply borrowed the finding of CIT(A)-IV, Surat, without seeing its relevance or reference and applied the fair market value on the assessee’s land. No addition under section 50C can be made in absence of any evidence. - AT
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