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...
Estate income administered by a sole executor falls under Section 168(1)(a) and must be assessed as if the executor were an individual. The maximum marginal rate applicable to an association of persons cannot be imposed merely by characterising the estate as an artificial juridical person. Verification of the testament and will is necessary to establish whether a sole executor administered the estate. On such verification, estate income is assessable at individual slab rates; the assessment was remitted to the Assessing Officer for this limited purpose.
Estate income administered by a sole executor falls under Section 168(1)(a) and must be assessed as if the executor were an individual. The maximum marginal rate applicable to an association of persons cannot be imposed merely by characterising the estate as an artificial juridical person. Verification of the testament and will is necessary to establish whether a sole executor administered the estate. On such verification, estate income is assessable at individual slab rates; the assessment was remitted to the Assessing Officer for this limited purpose.
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