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...
Additions u/s 56(2)(vii)(b) - purchase of immovable property - difference in value as per stamp duty valuation - since the Sale Deed itself got cancelled vide Cancellation Deed dated 26.02.2013 and the entire sale consideration was repaid to the assessee. Thus the question of invoking Section 56(2)(vii)(b) does not arise - AT
Additions u/s 56(2)(vii)(b) - purchase of immovable property - difference in value as per stamp duty valuation - since the Sale Deed itself got cancelled vide Cancellation Deed dated 26.02.2013 and the entire sale consideration was repaid to the assessee. Thus the question of invoking Section 56(2)(vii)(b) does not arise - AT
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