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...
Deduction u/s 54F or u/s 54 - mere sale of land instead of land and building - The cost of the property declared by the assessee includes an amount for making the house habitable which includes certain items as per serial No.1 to 16 of the table at para 5.5. of the CIT(A) which in our opinion is not allowable as a deduction for making the house habitable because these are all luxury items.CIT(A) has rightly determined the amount for making the house habitable. Therefore, the assessee is entitled to get the benefit of deduction u/s 54 of the Act to the extent including amount for making the house habitable. - AT
Deduction u/s 54F or u/s 54 - mere sale of land instead of land and building - The cost of the property declared by the assessee includes an amount for making the house habitable which includes certain items as per serial No.1 to 16 of the table at para 5.5. of the CIT(A) which in our opinion is not allowable as a deduction for making the house habitable because these are all luxury items.CIT(A) has rightly determined the amount for making the house habitable. Therefore, the assessee is entitled to get the benefit of deduction u/s 54 of the Act to the extent including amount for making the house habitable. - AT
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