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...
The ITAT ruled that the transfer of booking rights in a capital asset was completed in AY 2009-10, not AY 2008-09. The agreement to sell was contingent on builder's permission granted in 2008. Therefore, the capital gain addition in AY 2008-09 was deleted, and in AY 2009-10, it was converted from protective to substantive basis. The assessee's grounds were allowed.
The ITAT ruled that the transfer of booking rights in a capital asset was completed in AY 2009-10, not AY 2008-09. The agreement to sell was contingent on builder's permission granted in 2008. Therefore, the capital gain addition in AY 2008-09 was deleted, and in AY 2009-10, it was converted from protective to substantive basis. The assessee's grounds were allowed.
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