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...
Addition u/s 56 - transaction in shares - adequate consideration - Section 56(2)(viia) was brought in the statute book only w.e.f. 1st June, 2010 i.e. for AY 2011-12 - there was no reason to believe that there was any income on account of short fall in consideration paid during the AY 2010-11. - HC
Addition u/s 56 - transaction in shares - adequate consideration - Section 56(2)(viia) was brought in the statute book only w.e.f. 1st June, 2010 i.e. for AY 2011-12 - there was no reason to believe that there was any income on account of short fall in consideration paid during the AY 2010-11. - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
