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...
Section 56(2)(x) applies to any immovable property, so agricultural land purchased by the assessee was not from its scope merely because it was not a capital asset. The Tribunal held that the capital-asset character of agricultural land is relevant for the seller's capital gains computation, not for the buyer's liability under this provision, and therefore the addition was justified. It also found that the assessee had sought adoption of the DVO valuation instead of the higher stamp duty value and could not later challenge that very report or demand a fresh valuation exercise. The appeal was dismissed and the addition sustained.
Section 56(2)(x) applies to any immovable property, so agricultural land purchased by the assessee was not from its scope merely because it was not a capital asset. The Tribunal held that the capital-asset character of agricultural land is relevant for the seller's capital gains computation, not for the buyer's liability under this provision, and therefore the addition was justified. It also found that the assessee had sought adoption of the DVO valuation instead of the higher stamp duty value and could not later challenge that very report or demand a fresh valuation exercise. The appeal was dismissed and the addition sustained.
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