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...
Slump sale u/s 50B or not - Fresh Claim that transaction not liable to capital gain tax - investment in Tax Savings Bonds u/s 54EC - AO, CIT(A) and the Tribunal committed a fundamental error in shutting out the contention raised by the assessee solely on the ground that the assessee approached the Bond Issuing Authorities for availing the benefit u/s 54EC. A careful reading of the submissions made by the assessee before the AO would make things further clear. - There is no estoppel on the part of the assessee to pursue their claim and accordingly, we reject the argument of the Revenue in this regard. - HC
Slump sale u/s 50B or not - Fresh Claim that transaction not liable to capital gain tax - investment in Tax Savings Bonds u/s 54EC - AO, CIT(A) and the Tribunal committed a fundamental error in shutting out the contention raised by the assessee solely on the ground that the assessee approached the Bond Issuing Authorities for availing the benefit u/s 54EC. A careful reading of the submissions made by the assessee before the AO would make things further clear. - There is no estoppel on the part of the assessee to pursue their claim and accordingly, we reject the argument of the Revenue in this regard. - HC
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