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 u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
Addition u/s 50C r.w.s. 56(2)(vii) (b) - the buyer of the property - The Tribunal (ITAT) ruled that since the assesses were buyers, Section 50C did not apply, and Section 56(2)(vii)(b) did not apply as the property was not acquired without consideration. The retrospective application of Section 56(2)(vii)(b) was also rejected. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained. Consequently, the appeals by both assesses were allowed. Additionally, the Tribunal found no grounds for addition under Section 69C, as no show cause notice was issued and the initial addition was not sustained.
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