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...
LTCG or STCG - Sale of ground floor of residential unit - whether it give rise to long term capital gains or short term capital gains - Computation from period of holding from the date of getting right in the property or from the date of taking the possession - taking delivery of possession is only a formality. Therefore, reckoning the period from the date of advance, we hold that the sale of ground floor give raise to long term capital gains and not short term capital gains as held by the CIT. - AT
LTCG or STCG - Sale of ground floor of residential unit - whether it give rise to long term capital gains or short term capital gains - Computation from period of holding from the date of getting right in the property or from the date of taking the possession - taking delivery of possession is only a formality. Therefore, reckoning the period from the date of advance, we hold that the sale of ground floor give raise to long term capital gains and not short term capital gains as held by the CIT. - AT
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