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...
Treatment to income Declared under IDS-2016 - undisclosed income U/s. 68 r.w.s 115BBE OR capital gains - Merely because the assessee failed to discharge the tax liability under IDS-2016 as declared cannot change the character of the income under which it was declared under the IDS-2016. - Thus the income of the assessee shall be taxed as capital gains - To be taxed accordingly - AT
Treatment to income Declared under IDS-2016 - undisclosed income U/s. 68 r.w.s 115BBE OR capital gains - Merely because the assessee failed to discharge the tax liability under IDS-2016 as declared cannot change the character of the income under which it was declared under the IDS-2016. - Thus the income of the assessee shall be taxed as capital gains - To be taxed accordingly - AT
Note: It is a system-generated summary and is for quick reference only.
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