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...
Appellate Tribunal held that the Assessing Officer failed to provide findings for rejecting assessee's claim of exemption as a startup from applicability of section 56(2)(viib) regarding valuation of unquoted equity shares. Commissioner of Income Tax (Appeals) merely endorsed Assessing Officer's reasoning for not accepting valuation report without addressing assessee's claim. The issue was remanded to Assessing Officer to consider assessee's claim of startup exemption from section 56(2)(viib) after providing opportunity of hearing.
Appellate Tribunal held that the Assessing Officer failed to provide findings for rejecting assessee's claim of exemption as a startup from applicability of section 56(2)(viib) regarding valuation of unquoted equity shares. Commissioner of Income Tax (Appeals) merely endorsed Assessing Officer's reasoning for not accepting valuation report without addressing assessee's claim. The issue was remanded to Assessing Officer to consider assessee's claim of startup exemption from section 56(2)(viib) after providing opportunity of hearing.
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