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 on Account of LTCG u/s 50C - The appellant contended that the property was a litigated property, and thus not possible to sell at market rate, arguing that the provisions of section 50C should not apply. The appellant also highlighted that the difference between the valuation adopted by the Stamp Valuation Authority and that declared by the appellant was less than 10%, suggesting that the value declared by the appellant should be accepted. The ITAT, referring to a similar case involving Bhojison Infrastructure Pvt. Ltd., where the tribunal allowed the appeal favoring the appellant, found that the appellant's case was directly covered by this decision.
Addition on Account of LTCG u/s 50C - The appellant contended that the property was a litigated property, and thus not possible to sell at market rate, arguing that the provisions of section 50C should not apply. The appellant also highlighted that the difference between the valuation adopted by the Stamp Valuation Authority and that declared by the appellant was less than 10%, suggesting that the value declared by the appellant should be accepted. The ITAT, referring to a similar case involving Bhojison Infrastructure Pvt. Ltd., where the tribunal allowed the appeal favoring the appellant, found that the appellant's case was directly covered by this decision.
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