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...
LTCG - surrender of right sue under MOU and withdrawal of complaint before criminal court - compensation along with interest, towards loss of profit/liquidated damage for loss of opportunity to develop the property and sale of flats in the open market and towards the cost of litigation - amount received by the assessee in excess of advance is on account of compensation for extinction of its right to sue the owner, the receipt is a Capital receipt
LTCG - surrender of right sue under MOU and withdrawal of complaint before criminal court - compensation along with interest, towards loss of profit/liquidated damage for loss of opportunity to develop the property and sale of flats in the open market and towards the cost of litigation - amount received by the assessee in excess of advance is on account of compensation for extinction of its right to sue the owner, the receipt is a Capital receipt
Note: It is a system-generated summary and is for quick reference only.
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