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...
Five independent flats treated as single unit u/s 54F – the built up area got translated into five flats - the transaction was not with regard to the number of flats but with regard to the percentage of the built up area, vis-a-vis, the Undivided Share of Land - property should be assessed as one unit - HC
Five independent flats treated as single unit u/s 54F – the built up area got translated into five flats - the transaction was not with regard to the number of flats but with regard to the percentage of the built up area, vis-a-vis, the Undivided Share of Land - property should be assessed as one unit - HC
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