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 upheld the AO and CIT(A)'s adoption of the stamp duty value of Rs.67,14,284 as full value of consideration under s.50C, finding no infirmity and noting no request for DVO reference. On s.54 exemption, ITAT accepted in principle the assessee's asserted 2:1 contribution ratio to the new residential property and directed the AO to verify actual contributions of the assessee and spouse and grant exemption proportionately if substantiated. Regarding indexed cost of improvements, ITAT found the absence of bank entry not determinative given the antiquity of the works and directed the AO to allow the claimed indexed improvement cost if contractor bills and supporting evidence credibly establish payment.
ITAT upheld the AO and CIT(A)'s adoption of the stamp duty value of Rs.67,14,284 as full value of consideration under s.50C, finding no infirmity and noting no request for DVO reference. On s.54 exemption, ITAT accepted in principle the assessee's asserted 2:1 contribution ratio to the new residential property and directed the AO to verify actual contributions of the assessee and spouse and grant exemption proportionately if substantiated. Regarding indexed cost of improvements, ITAT found the absence of bank entry not determinative given the antiquity of the works and directed the AO to allow the claimed indexed improvement cost if contractor bills and supporting evidence credibly establish payment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
