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...
Exemption u/s 54EC - Since assessee had invested ₹ 71 lakhs in two different financial years and within six months from the date of transfer of the capital assets, the limit of ₹ 50 lakhs is per financial year. Hence, the assessee is eligible for deduction of ₹ 71 lakhs u/s 54EC - AT
Exemption u/s 54EC - Since assessee had invested ₹ 71 lakhs in two different financial years and within six months from the date of transfer of the capital assets, the limit of ₹ 50 lakhs is per financial year. Hence, the assessee is eligible for deduction of ₹ 71 lakhs u/s 54EC - AT
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