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...
House property - Disallowance of interest claimed on second loan u/s.24(b) - Applicability of DBDT circular - Ld. CIT(A) recorded categorical findings that the assessee has used second loan to re-pay existing loan and there is a nexus between loan borrowed from purchase of property and thus, the assessee is entitled for deduction towards interest paid on second loan. - Claim allowed - AT
House property - Disallowance of interest claimed on second loan u/s.24(b) - Applicability of DBDT circular - Ld. CIT(A) recorded categorical findings that the assessee has used second loan to re-pay existing loan and there is a nexus between loan borrowed from purchase of property and thus, the assessee is entitled for deduction towards interest paid on second loan. - Claim allowed - AT
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