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...
Set off the business losses against the capital gains u/s 71 - The assessee in the return of income did not set off the business loss against the short term capital gain. However, after adjusting the capital gains of the year against the brought forward short term capital loss and claiming deduction u/s 80 returned the taxable income at ‘nil’ with carry forward business loss - Action of the assessee confirmed.
Set off the business losses against the capital gains u/s 71 - The assessee in the return of income did not set off the business loss against the short term capital gain. However, after adjusting the capital gains of the year against the brought forward short term capital loss and claiming deduction u/s 80 returned the taxable income at ‘nil’ with carry forward business loss - Action of the assessee confirmed.
Note: It is a system-generated summary and is for quick reference only.
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