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...
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
In valuation of house construction for unexplained investment, local State PWD rates were preferred over CPWD rates because they better reflect market conditions. The Tribunal also allowed a 15% deduction for self-supervision where no technical person was employed, after noting that the appellate authority had already corrected valuation defects and accepted the relevant measurements. After applying the rate adjustment and self-supervision relief, the difference with the books fell within the 5% tolerance band. No addition for cost of construction was therefore warranted, and the disputed valuation addition was deleted.
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