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...
Rental income from letting out of the factory building - Profits and gains of business or profession OR Income from Other Sources - the intention of the assessee was to lease out both the assets to the same lessee and the usage of the two assets was inseparable. - The income earned by the assessee, under both the streams, have rightly been held to be assessable u/s 56(2)(iii) which provide for assessment of income as Income from other sources - AT
Rental income from letting out of the factory building - Profits and gains of business or profession OR Income from Other Sources - the intention of the assessee was to lease out both the assets to the same lessee and the usage of the two assets was inseparable. - The income earned by the assessee, under both the streams, have rightly been held to be assessable u/s 56(2)(iii) which provide for assessment of income as Income from other sources - AT
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