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...
Assessee entitled to exemption u/s 54F/54 as possession of new house property acquired within one year before sale of original asset; crucial date for purchase is when possession and control given to purchaser, not legal transfer; mere allegation of fabricated document cannot be sustained without evidence; reliance on precedents of Shahzada Begum, Laxmichand Nagda, and T.N. Aravinda Reddy cases.
Assessee entitled to exemption u/s 54F/54 as possession of new house property acquired within one year before sale of original asset; crucial date for purchase is when possession and control given to purchaser, not legal transfer; mere allegation of fabricated document cannot be sustained without evidence; reliance on precedents of Shahzada Begum, Laxmichand Nagda, and T.N. Aravinda Reddy cases.
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