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 subsidy received under TUF scheme - revenue or capital receipts or reduction in value of fixed assets - to reduce from the cost of asset, the subsidy should be directly or indirectly used for acquiring an asset - In present case no asset was being acquired by using TUF subsidy therefore it should not be reduced from fixed assets - hence, such TUF subsidy is to be treated capital receipt
Taxability of subsidy received under TUF scheme - revenue or capital receipts or reduction in value of fixed assets - to reduce from the cost of asset, the subsidy should be directly or indirectly used for acquiring an asset - In present case no asset was being acquired by using TUF subsidy therefore it should not be reduced from fixed assets - hence, such TUF subsidy is to be treated capital receipt
Note: It is a system-generated summary and is for quick reference only.
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