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...
Disallowance of capital loss on account of capital reduction scheme - Extinguishment of rights in shares - definition of ‘transfer’ u/s 2(47) - Loss arising to the assessee for cancellation of its shares in CHIPL pursuant to reduction of capital should be allowed as long term capital loss eligible to be carried forward to subsequent years.
Disallowance of capital loss on account of capital reduction scheme - Extinguishment of rights in shares - definition of ‘transfer’ u/s 2(47) - Loss arising to the assessee for cancellation of its shares in CHIPL pursuant to reduction of capital should be allowed as long term capital loss eligible to be carried forward to subsequent years.
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