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...
Rental receipts from commercial spaces let out in an organised manner with utilities, amenities and staff were held taxable as business income, because the assessee's dominant activity was commercial exploitation of business assets rather than mere ownership of property. The Tribunal also applied the rule of consistency, noting that the Revenue had accepted the same treatment in earlier scrutiny years without any change in facts or law. The assessment under the head house property was vacated. An estimated disallowance of expenses was deleted because the assessee had produced supporting details, no specific defect in expenditure was identified, the books were not rejected, and the factual basis for the disallowance was incorrect.
Rental receipts from commercial spaces let out in an organised manner with utilities, amenities and staff were held taxable as business income, because the assessee's dominant activity was commercial exploitation of business assets rather than mere ownership of property. The Tribunal also applied the rule of consistency, noting that the Revenue had accepted the same treatment in earlier scrutiny years without any change in facts or law. The assessment under the head house property was vacated. An estimated disallowance of expenses was deleted because the assessee had produced supporting details, no specific defect in expenditure was identified, the books were not rejected, and the factual basis for the disallowance was incorrect.
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