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 STCG - Capital gain on sale of equity shares - period of holding of shares - There exists a clause for condition precedent to the sale which has to be fulfilled by both the vendor and the purchaser - The Appellate Tribunal's decision focused on the interpretation of the "date of transfer" of shares. The Tribunal cited several precedents, including the decision of the Delhi High Court in Bharti Gupta Ramola vs. CIT and similar Tribunal decisions, which supported the assessee's contention that the transfer date should be recognized as the date when all substantive conditions of the share transfer agreement were fulfilled. The Tribunal concluded that the shares were held for more than 12 months and therefore qualified for LTCG treatment.
LTCG OR STCG - Capital gain on sale of equity shares - period of holding of shares - There exists a clause for condition precedent to the sale which has to be fulfilled by both the vendor and the purchaser - The Appellate Tribunal's decision focused on the interpretation of the "date of transfer" of shares. The Tribunal cited several precedents, including the decision of the Delhi High Court in Bharti Gupta Ramola vs. CIT and similar Tribunal decisions, which supported the assessee's contention that the transfer date should be recognized as the date when all substantive conditions of the share transfer agreement were fulfilled. The Tribunal concluded that the shares were held for more than 12 months and therefore qualified for LTCG treatment.
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