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. 24(a) equal to 30% - Rental income from fixture, fittings and amenities - separate agreements for let out of the property and for providing amenities - The principle of res judicata does not apply to tax proceedings, but the rule of consistency must be respected unless there are new facts. - the rule of consistency supports the claim of the assessee that the rental income from amenities must be treated as income from house property and is eligible for a deduction under section 24(a) of the Act - AT
Deduction u/s. 24(a) equal to 30% - Rental income from fixture, fittings and amenities - separate agreements for let out of the property and for providing amenities - The principle of res judicata does not apply to tax proceedings, but the rule of consistency must be respected unless there are new facts. - the rule of consistency supports the claim of the assessee that the rental income from amenities must be treated as income from house property and is eligible for a deduction under section 24(a) of the Act - AT
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