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...
Correct head of income - compensation received for vacating the flat - While the assessee argued for capital gain treatment, the Revenue contended it should be classified as income from other sources. However, the ITAT ruled that the compensation constituted a capital receipt in the hands of the assessee, as it was received from the company out of its own income. The ITAT concluded that the amount was neither capital gain nor income from other sources but rather an application of income by the company. Therefore, the addition made by the assessing officer was deleted, and the appeal of the assessee was allowed.
Correct head of income - compensation received for vacating the flat - While the assessee argued for capital gain treatment, the Revenue contended it should be classified as income from other sources. However, the ITAT ruled that the compensation constituted a capital receipt in the hands of the assessee, as it was received from the company out of its own income. The ITAT concluded that the amount was neither capital gain nor income from other sources but rather an application of income by the company. Therefore, the addition made by the assessing officer was deleted, and the appeal of the assessee was allowed.
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