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 ruled in favor of assessee on two key issues. First, the allegation of "on-money" payment for residential property was rejected as the difference between actual payment and registered value cannot be deemed undisclosed income when payments were made through verified banking channels and loan disbursements. Second, DRP's direction to AO for further verification post-DRP proceedings was held ultra vires as per Sec 144C. DRP must conduct verifications during proceedings under 144C(7), not after issuing directions. AO must complete assessment within one month of receiving DRP directions without additional inquiry. Consequently, the addition made in Final Assessment Order was held without jurisdiction and deleted.
ITAT ruled in favor of assessee on two key issues. First, the allegation of "on-money" payment for residential property was rejected as the difference between actual payment and registered value cannot be deemed undisclosed income when payments were made through verified banking channels and loan disbursements. Second, DRP's direction to AO for further verification post-DRP proceedings was held ultra vires as per Sec 144C. DRP must conduct verifications during proceedings under 144C(7), not after issuing directions. AO must complete assessment within one month of receiving DRP directions without additional inquiry. Consequently, the addition made in Final Assessment Order was held without jurisdiction and deleted.
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