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...
Additions on account of long term capital gains arising from transfer of land - GPA holder - when in the registered power of attorney no consideration has passed on from assessee to the original owner, there was no question of any transfer of property in favour of the assessee. - He has merely acted upon GPA - No additions in the hands of GPA holder.
Additions on account of long term capital gains arising from transfer of land - GPA holder - when in the registered power of attorney no consideration has passed on from assessee to the original owner, there was no question of any transfer of property in favour of the assessee. - He has merely acted upon GPA - No additions in the hands of GPA holder.
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