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...
LTCG OR business income - entitlement to exemption u/s 54F - Disallowance u/s 14A r.w.r. 8D - Tribunal decided in favor of the assessee for the treatment of income as capital gains, citing past precedents and evidence supporting the nature of investments. However, they partly allowed the appeal concerning disallowance of administrative expenses due to lack of justification.
LTCG OR business income - entitlement to exemption u/s 54F - Disallowance u/s 14A r.w.r. 8D - Tribunal decided in favor of the assessee for the treatment of income as capital gains, citing past precedents and evidence supporting the nature of investments. However, they partly allowed the appeal concerning disallowance of administrative expenses due to lack of justification.
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