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 54 - LTCG invested in buying two residential units - the assessee would only entitle to the benefit of section 54, 1) if the assessee invested the LTCG amount for buying one residential house or 2) if the assessee purchased one residential house which was made after merger of two residential units already amalgamated and were in existence as one residential unit - However the assessee is not entitled to benefit of LTCG invested in buying two residential units and thereafter converting the said two residential units as one. - AT
Deduction u/s 54 - LTCG invested in buying two residential units - the assessee would only entitle to the benefit of section 54, 1) if the assessee invested the LTCG amount for buying one residential house or 2) if the assessee purchased one residential house which was made after merger of two residential units already amalgamated and were in existence as one residential unit - However the assessee is not entitled to benefit of LTCG invested in buying two residential units and thereafter converting the said two residential units as one. - AT
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