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 rental income - Income from House Property or Business income - Deemed owner - assessee was entitled to have access to operate, manage and maintain the Licensed Space at the Specified Area during the License Period - No semblance of any characteristics of transactions for which Section 53A of the Act is applicable and there is no question of assessee being a deemed owner, so as to account for rent as income from property and not business income. - AT
Nature of rental income - Income from House Property or Business income - Deemed owner - assessee was entitled to have access to operate, manage and maintain the Licensed Space at the Specified Area during the License Period - No semblance of any characteristics of transactions for which Section 53A of the Act is applicable and there is no question of assessee being a deemed owner, so as to account for rent as income from property and not business income. - AT
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