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...
Wealth Tax Liability - Whether Club can be treated as "Association of Person"? - Section 21AA has been introduced in order to prevent tax evasion - The Bangalore Club is an association of persons and not the creation, by a person who is otherwise assessable, of one among a large number of associations of persons without defining the shares of the members so as to escape tax liability. - It is clear that Section 21AA of the Wealth Tax Act does not get attracted to the facts of the present case. - SC
Wealth Tax Liability - Whether Club can be treated as "Association of Person"? - Section 21AA has been introduced in order to prevent tax evasion - The Bangalore Club is an association of persons and not the creation, by a person who is otherwise assessable, of one among a large number of associations of persons without defining the shares of the members so as to escape tax liability. - It is clear that Section 21AA of the Wealth Tax Act does not get attracted to the facts of the present case. - SC
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