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...
Taxability of capital gains - denial of adjustments to full value of sale consideration towards amount lying in Escrow account while determining the LTCG - ITAT accepted the revised computation of capital gains, excluding the amount retained in the escrow account, which was neither received nor expected to be received by the assessee due to subsequent events indicating significant liabilities against the escrow. - As conceded on behalf of the assessee, the amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual.
Taxability of capital gains - denial of adjustments to full value of sale consideration towards amount lying in Escrow account while determining the LTCG - ITAT accepted the revised computation of capital gains, excluding the amount retained in the escrow account, which was neither received nor expected to be received by the assessee due to subsequent events indicating significant liabilities against the escrow. - As conceded on behalf of the assessee, the amount recovered out of escrow account by the assessee in the later years shall be liable to taxation in the respective years of receipt or accrual.
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