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...
Industrial gala sold - taxation as STCG or LTCG - The entire payment as per the agreement was in fact made before financial year 1998-99. Occupation certificate was also issued on 10.03.1998 - the keys were taken back by the assessee on 01.01.2005 - sale of the property in the year 2005 has to be treated as sale of long-term capital assets and gain has to be assessed as long-term-capital-gain - AT
Industrial gala sold - taxation as STCG or LTCG - The entire payment as per the agreement was in fact made before financial year 1998-99. Occupation certificate was also issued on 10.03.1998 - the keys were taken back by the assessee on 01.01.2005 - sale of the property in the year 2005 has to be treated as sale of long-term capital assets and gain has to be assessed as long-term-capital-gain - AT
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