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...
Nature of receipt - amount received by the assessee firm as a compensation for pre-closure of its BOT projects - Revenue or capital receipt - both the learned authorities have erred in law and on facts in invoking section 28(ii)(d) qua assessee’s impugned compensation thereby holding it as a revenue receipt. The assessee succeeds. - AT
Nature of receipt - amount received by the assessee firm as a compensation for pre-closure of its BOT projects - Revenue or capital receipt - both the learned authorities have erred in law and on facts in invoking section 28(ii)(d) qua assessee’s impugned compensation thereby holding it as a revenue receipt. The assessee succeeds. - AT
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