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...
Sale of patent/ know-how known as “Profofal” - disputed amount is taxable as capital receipt/ gains u/s. 55 (2) - The assessee was not in the business of purchase and sale of patents, so the sale proceed of the assignment agreement could not be treated a revenue receipt. - AT
Sale of patent/ know-how known as “Profofal” - disputed amount is taxable as capital receipt/ gains u/s. 55 (2) - The assessee was not in the business of purchase and sale of patents, so the sale proceed of the assignment agreement could not be treated a revenue receipt. - AT
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