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...
In the ITAT Delhi case, the Appellate Tribunal ruled in favor of the assessee on two key issues. Firstly, regarding unexplained cash deposits u/s 68, the AO's failure to consider cash balances and debtor realizations led to the addition being deemed unsustainable. The Tribunal directed the AO to delete the addition. Secondly, on the disallowance of interest paid u/s 36(1)(iii), the Tribunal accepted the assessee's argument that interest on bank loans is a business expenditure, given the assessee's history of real estate and finance business activities. The disallowance made by the AO was deleted based on the Tribunal's decision for the assessment year 2009-10, affirming the assessee's real estate business activities.
In the ITAT Delhi case, the Appellate Tribunal ruled in favor of the assessee on two key issues. Firstly, regarding unexplained cash deposits u/s 68, the AO's failure to consider cash balances and debtor realizations led to the addition being deemed unsustainable. The Tribunal directed the AO to delete the addition. Secondly, on the disallowance of interest paid u/s 36(1)(iii), the Tribunal accepted the assessee's argument that interest on bank loans is a business expenditure, given the assessee's history of real estate and finance business activities. The disallowance made by the AO was deleted based on the Tribunal's decision for the assessment year 2009-10, affirming the assessee's real estate business activities.
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