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...
Amendment in special tax regime for REIT & INVIT - To avoid dual Non-taxation in the hands of unit holders as well as business trust on any income distributed by such business trust therefore the amendment proposed for REIT/InVIT related to distribution by manner of 'Repayment of debt' to the unitholders is now covered under the ambit of taxation as other income (net of cost of acquisition of the unit) which earlier was not captured.
Amendment in special tax regime for REIT & INVIT - To avoid dual Non-taxation in the hands of unit holders as well as business trust on any income distributed by such business trust therefore the amendment proposed for REIT/InVIT related to distribution by manner of 'Repayment of debt' to the unitholders is now covered under the ambit of taxation as other income (net of cost of acquisition of the unit) which earlier was not captured.
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