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 gain/ loss on sale of property - unregistered sale agreement - whether it constitute valid transfer under section 53A of Transfer of Property Act - There is no requirement within the meaning of the word "transfer" as per Income Tax Act for the charge ability of capital gains, for the registration of property as long as the possession and part consideration has been effected with regard to the subject property. - AT
Capital gain/ loss on sale of property - unregistered sale agreement - whether it constitute valid transfer under section 53A of Transfer of Property Act - There is no requirement within the meaning of the word "transfer" as per Income Tax Act for the charge ability of capital gains, for the registration of property as long as the possession and part consideration has been effected with regard to the subject property. - AT
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