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 held that the assessee's property transaction did not constitute a short-term capital gain. The tribunal found no evidence of actual property transfer or possession, and the total consideration paid (Rs. 5,00,20,000) exceeded the market valuation (Rs. 4,74,00,000). The unregistered agreement was not considered a valid sale deed. The appellate tribunal set aside the lower authorities' order, directing the AO to delete additions under section 56(vii)(b), effectively allowing the assessee's appeal and rejecting revenue's claims of undervaluation.
ITAT held that the assessee's property transaction did not constitute a short-term capital gain. The tribunal found no evidence of actual property transfer or possession, and the total consideration paid (Rs. 5,00,20,000) exceeded the market valuation (Rs. 4,74,00,000). The unregistered agreement was not considered a valid sale deed. The appellate tribunal set aside the lower authorities' order, directing the AO to delete additions under section 56(vii)(b), effectively allowing the assessee's appeal and rejecting revenue's claims of undervaluation.
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