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...
Benami Property Transaction - title over the suit properties - Moreover purchase of a property by husband in the name of the wife cannot be called a benami transaction and such type of transaction falls within the exception no. 3 to clause 'A' of sub-section 9 of section 2 of the Prohibition of Benami Property Transactions Act, 1988. In this view the respondent has made out a prima facie case that he has got the right to seek declaration of his title over the suit properties. - HC
Benami Property Transaction - title over the suit properties - Moreover purchase of a property by husband in the name of the wife cannot be called a benami transaction and such type of transaction falls within the exception no. 3 to clause 'A' of sub-section 9 of section 2 of the Prohibition of Benami Property Transactions Act, 1988. In this view the respondent has made out a prima facie case that he has got the right to seek declaration of his title over the suit properties. - HC
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