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...
ITAT reversed CIT(A)'s addition under s.69 regarding unexplained property investment, accepting loan from assessee's mother as legitimate source after verification of her creditworthiness in reopened assessment. On interest disallowance under s.24, ITAT directed AO to verify if assessee's investment from borrowed funds was limited to their ownership share. Interest deduction permitted only on borrowed funds used for initial property investment up to assessee's share portion, following prudent investment principle. Subsequent investments, even if from borrowed funds, deemed ineligible for s.24 interest deduction. Matter remanded to AO for verification of fund utilization patterns in bank accounts and determination of allowable interest based on initial investment share.
ITAT reversed CIT(A)'s addition under s.69 regarding unexplained property investment, accepting loan from assessee's mother as legitimate source after verification of her creditworthiness in reopened assessment. On interest disallowance under s.24, ITAT directed AO to verify if assessee's investment from borrowed funds was limited to their ownership share. Interest deduction permitted only on borrowed funds used for initial property investment up to assessee's share portion, following prudent investment principle. Subsequent investments, even if from borrowed funds, deemed ineligible for s.24 interest deduction. Matter remanded to AO for verification of fund utilization patterns in bank accounts and determination of allowable interest based on initial investment share.
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