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...
Computation of Period of holding - Transferable Development Rights(TDR) - for the purpose of determination of period of holding, the holding of the TDR from the date of acquisition of property by the municipal authorities has to be considered, not from the date, when MOU was cancelled, then the period of holding of the asset is more than 36 months and hence, surplus is rightly assessable under the head lTCG
Computation of Period of holding - Transferable Development Rights(TDR) - for the purpose of determination of period of holding, the holding of the TDR from the date of acquisition of property by the municipal authorities has to be considered, not from the date, when MOU was cancelled, then the period of holding of the asset is more than 36 months and hence, surplus is rightly assessable under the head lTCG
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