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...
Period of holding - Whether sale of ESOP constitutes long term (LTCG) or short term capital gains (STCG) - The benefit of deferment of purchase price cannot lead to an inference that no right accrued to assessee - Held as LTCG - AT
Period of holding - Whether sale of ESOP constitutes long term (LTCG) or short term capital gains (STCG) - The benefit of deferment of purchase price cannot lead to an inference that no right accrued to assessee - Held as LTCG - AT
Note: It is a system-generated summary and is for quick reference only.
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