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 of income u/s 56(2)(x)(b)(B) - under valuation of stamp duty value on purchase consideration of the property u/s 50C - The assessee asserts that only a partial amount of the purchase consideration was paid, and the transaction is embroiled in a legal dispute, hence section 50C should not be applicable. - The ITAT noted that despite the assessee's claim of only a partial payment, the sale deed indicated otherwise. As a result, the tribunal upholds the addition to the assessee's income under section 56(2)(x)(b)(B) for the differential amount between the stamp value and the purchase consideration.
Addition of income u/s 56(2)(x)(b)(B) - under valuation of stamp duty value on purchase consideration of the property u/s 50C - The assessee asserts that only a partial amount of the purchase consideration was paid, and the transaction is embroiled in a legal dispute, hence section 50C should not be applicable. - The ITAT noted that despite the assessee's claim of only a partial payment, the sale deed indicated otherwise. As a result, the tribunal upholds the addition to the assessee's income under section 56(2)(x)(b)(B) for the differential amount between the stamp value and the purchase consideration.
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