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...
Disallowing the claim of capital loss incurred by the appellant due to reduction of capital by the investee company - transfer u/s 2(47) - face value of shares remains the same - assessee’s claim for capital loss on account of reduction in share capital in ANNPL is allowable
Disallowing the claim of capital loss incurred by the appellant due to reduction of capital by the investee company - transfer u/s 2(47) - face value of shares remains the same - assessee’s claim for capital loss on account of reduction in share capital in ANNPL is allowable
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