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...
Non-compete fees receipt - taxability under Section 17(3)(iii) or 28(va) as salary income or business income or not - profit in lieu of salary - assessee is an individual and was Financial Director - it cannot be inferred that the said agreement in any way intended to compensate the assessee for loss of employment or in lieu of salary - amount is not taxable - AT
Non-compete fees receipt - taxability under Section 17(3)(iii) or 28(va) as salary income or business income or not - profit in lieu of salary - assessee is an individual and was Financial Director - it cannot be inferred that the said agreement in any way intended to compensate the assessee for loss of employment or in lieu of salary - amount is not taxable - AT
Note: It is a system-generated summary and is for quick reference only.
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