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...
Addition u/s 56(2)(vii)(b) - difference between the sale consideration declared by the assessee and the stamp duty value - since the difference between the sale consideration declared by the assessee and the stamp duty value is 5.8% (approx), the consideration declared by the assessee should not be disturbed as the variation is within tolerance band of 10%. - AT
Addition u/s 56(2)(vii)(b) - difference between the sale consideration declared by the assessee and the stamp duty value - since the difference between the sale consideration declared by the assessee and the stamp duty value is 5.8% (approx), the consideration declared by the assessee should not be disturbed as the variation is within tolerance band of 10%. - AT
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