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 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.
Section 87A does not expressly bar rebate against tax payable on short-term capital gains from listed equity shares taxed at the special rate under section 111A. Applying a plain reading of both provisions and following the cited Tribunal precedent, rebate under section 87A is available in respect of such tax liability. Denial of the claimed rebate was therefore unsustainable, and the Assessing Officers were directed to grant it.
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