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...
Income from sale of shares - business income OR capital gain - trading of under lying assets (land) of the subsidiary companies - sale of shares can not be treated as trading in land so as to be taxed as business income in the hands of the assessee.
Income from sale of shares - business income OR capital gain - trading of under lying assets (land) of the subsidiary companies - sale of shares can not be treated as trading in land so as to be taxed as business income in the hands of the assessee.
Note: It is a system-generated summary and is for quick reference only.
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