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 allowed the assessee's appeal in part, holding that payments made to the builder for civil, plumbing and electrical works constituted part of cost of acquisition and permitting Rs.11,35,023 as cost of acquisition, noting receipts and payment statements and absence of bank records due to account closure. Concurrently ITAT sustained exclusion of certain improvement claims, directing the AO to disallow Rs.5,49,644 as personal effects or non-deductible items, while accepting that embedded permanent fixtures qualify as part of capital improvement. Claims for air travel, boarding, meals, local transport and related expenses were disallowed as not incurred "wholly and exclusively" in connection with the transfer.
ITAT allowed the assessee's appeal in part, holding that payments made to the builder for civil, plumbing and electrical works constituted part of cost of acquisition and permitting Rs.11,35,023 as cost of acquisition, noting receipts and payment statements and absence of bank records due to account closure. Concurrently ITAT sustained exclusion of certain improvement claims, directing the AO to disallow Rs.5,49,644 as personal effects or non-deductible items, while accepting that embedded permanent fixtures qualify as part of capital improvement. Claims for air travel, boarding, meals, local transport and related expenses were disallowed as not incurred "wholly and exclusively" in connection with the transfer.
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