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...
Computation of capital Gain - Disallowance being expenses towards the additional work undertaken by the assessee in respect of the flat purchased by her for a consideration - The Tribunal accepted the assessee's evidence, including bank statements and agreements with contractors, as sufficient proof of the additional construction work. Recognized that the housing loan was jointly taken by the assessee and her husband for purchasing and improving the flat. Confirmed that the entire transaction, including the additional work and loan repayment, was reflected in the assessee's accounts. Disallowed the AO's findings due to lack of contrary evidence and deleted the addition.
Computation of capital Gain - Disallowance being expenses towards the additional work undertaken by the assessee in respect of the flat purchased by her for a consideration - The Tribunal accepted the assessee's evidence, including bank statements and agreements with contractors, as sufficient proof of the additional construction work. Recognized that the housing loan was jointly taken by the assessee and her husband for purchasing and improving the flat. Confirmed that the entire transaction, including the additional work and loan repayment, was reflected in the assessee's accounts. Disallowed the AO's findings due to lack of contrary evidence and deleted the addition.
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