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...
Taxability of shares premium u/s 56(2)(viib) - AO was required to undertake the exercise of fact finding by determining the FMV of the Shares in question as per Explanation to Section 56(2)(viib) - remanded back to AO because such exercise not having been done - the Assessee will be free to raise all factual and legal contentions including treating said amount as 'gift' from mother to daughter.
Taxability of shares premium u/s 56(2)(viib) - AO was required to undertake the exercise of fact finding by determining the FMV of the Shares in question as per Explanation to Section 56(2)(viib) - remanded back to AO because such exercise not having been done - the Assessee will be free to raise all factual and legal contentions including treating said amount as 'gift' from mother to daughter.
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