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...
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
Common area maintenance recoveries treated as business income supported allowance of related expenditure, and proportionate disallowance by reference to house property income was rejected where the assessee was contractually responsible only for common areas of the mall. Repairs and maintenance, legal and professional fees, employee remuneration, advertisement and sales promotion, and security charges were each held to be linked to mall management and CAM obligations rather than to rental income, subject only to limited factual restriction in respect of office and general expenses. The Tribunal also upheld the appellate authority's power to entertain and direct verification of an additional property tax deduction claim arising from the record.
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