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...
A composite lease of tea estates was held to be an agricultural arrangement, not taxable renting of immovable property, because it was directed to plantation operations such as cultivation, harvesting and processing of green tea leaves, with consideration linked to agricultural output. The Tribunal held that land, labour quarters, staff facilities and machinery integral to plantation activity could not be artificially split into separate taxable services, and the demands for manpower supply and supply of tangible goods also failed because there was no independent consideration, possession, or effective control by the recipient. The impugned orders were set aside, and limitation, interest and penalties did not survive.
A composite lease of tea estates was held to be an agricultural arrangement, not taxable renting of immovable property, because it was directed to plantation operations such as cultivation, harvesting and processing of green tea leaves, with consideration linked to agricultural output. The Tribunal held that land, labour quarters, staff facilities and machinery integral to plantation activity could not be artificially split into separate taxable services, and the demands for manpower supply and supply of tangible goods also failed because there was no independent consideration, possession, or effective control by the recipient. The impugned orders were set aside, and limitation, interest and penalties did not survive.
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