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...
Revenue receipt or capital receipt - Foreign exchange gain written back on cancellation of vessel construction contract taxed u/s. 28(iv) - The ITAT agreed with the assessee, holding that the gain was a capital receipt not taxable under Section 28(iv) of the Act. This decision underscores the differentiation between capital and revenue receipts, particularly in the context of foreign exchange gains related to capital assets.
Revenue receipt or capital receipt - Foreign exchange gain written back on cancellation of vessel construction contract taxed u/s. 28(iv) - The ITAT agreed with the assessee, holding that the gain was a capital receipt not taxable under Section 28(iv) of the Act. This decision underscores the differentiation between capital and revenue receipts, particularly in the context of foreign exchange gains related to capital assets.
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