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...
Income from house property - consider the Ambey Valley property as self-occupied property - determination of annual value - CIT(A) has upheld that the 7% of cost of property as annual value taxable u/s 23, against the assessee and therefore only others ground are which are allowed by him. There is no reason given by him. Therefore, we restore ground back to the file of Ld. CIT(A) to give clear cut reason and finding that whether the claim of the assessee of considering Ambey Valley property as self-occupied property u/s 23(2) of the Act is allowable or not. - AT
Income from house property - consider the Ambey Valley property as self-occupied property - determination of annual value - CIT(A) has upheld that the 7% of cost of property as annual value taxable u/s 23, against the assessee and therefore only others ground are which are allowed by him. There is no reason given by him. Therefore, we restore ground back to the file of Ld. CIT(A) to give clear cut reason and finding that whether the claim of the assessee of considering Ambey Valley property as self-occupied property u/s 23(2) of the Act is allowable or not. - AT
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