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...
Capital Gains - Whether land belonged to the ''HUF'' and not to the assessee? - there was no mentioned that the land was being sold by the assessee as Karta of 'HUF' - proceeds of the sale were also deposited/retained by the assessee in his individual capacity and further the land so purchased out of the proceeds of the sale was also in the name of the assessee in individual capacity - plea that the income/capital gains should have been assessed in the name of the 'HUF' seems to be an afterthought. - AT
Capital Gains - Whether land belonged to the ''HUF'' and not to the assessee? - there was no mentioned that the land was being sold by the assessee as Karta of 'HUF' - proceeds of the sale were also deposited/retained by the assessee in his individual capacity and further the land so purchased out of the proceeds of the sale was also in the name of the assessee in individual capacity - plea that the income/capital gains should have been assessed in the name of the 'HUF' seems to be an afterthought. - AT
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