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 of capital loss - tax planning vs tax avoidance - shares were held by assessee for long period - transaction has not been doubted - sold at a price which was more than NAV value of shares as on date of sale of shares- allowable even if it is a case of tax planning within four corners of law and the same cannot be brushed aside.
Set off of capital loss - tax planning vs tax avoidance - shares were held by assessee for long period - transaction has not been doubted - sold at a price which was more than NAV value of shares as on date of sale of shares- allowable even if it is a case of tax planning within four corners of law and the same cannot be brushed aside.
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