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...
Exemption u/s 54 - sale of house constructed on leased land - as per revenue in order to claim benefit of u/s 54, must also transfer the land appurtenant thereto - what is important is that there should be a transfer of capital asset being a building or land appurtenant thereto and being a residential house - The word 'or' cannot be read as 'and' in the context of section 54
Exemption u/s 54 - sale of house constructed on leased land - as per revenue in order to claim benefit of u/s 54, must also transfer the land appurtenant thereto - what is important is that there should be a transfer of capital asset being a building or land appurtenant thereto and being a residential house - The word 'or' cannot be read as 'and' in the context of section 54
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