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...
Nature of loss - business loss or short term capital loss - the fact remains that the assessee is engaged in property development business and developing residential projects throughout all preceding assessment years - mere book treatment of the land in issue as a fixed asset cannot form the sole criteria to hold that the same gives rise to capital loss - considered as business loss
Nature of loss - business loss or short term capital loss - the fact remains that the assessee is engaged in property development business and developing residential projects throughout all preceding assessment years - mere book treatment of the land in issue as a fixed asset cannot form the sole criteria to hold that the same gives rise to capital loss - considered as business loss
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