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 invoking provisions u/s 56(2)(vii)(b) - assessee only received lease hold right for 99 years - difference of stamp value minus sales consideration - The definition of property does not refer to rights or transactions which may enable use or enjoyment of property and it appears that having regards to description context and objective, acquisition of such rights cannot be equated with immovable property. - AT
Addition invoking provisions u/s 56(2)(vii)(b) - assessee only received lease hold right for 99 years - difference of stamp value minus sales consideration - The definition of property does not refer to rights or transactions which may enable use or enjoyment of property and it appears that having regards to description context and objective, acquisition of such rights cannot be equated with immovable property. - AT
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