Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
Capital gains computation - cost of acquisition relates back to date of transfer through will/family settlement to beneficiary. Determination of indexed cost of acquisition for residential property acquired through family settlement. Additional evidence not admissible before ITAT without following rules. Family settlement is not a transfer, cost of acquisition relates back to previous owner's acquisition. Family settlement need not be registered if recording prior arrangement. For capital gains, cost inflation index calculated from year property acquired by previous owner through registered deed. Family arrangement does not involve transfer, hence no capital gains tax. Calculation based on indexed cost from previous owner's acquisition date, even if will disregarded. Order of CIT(A) upheld, decided in favor of assessee.
Capital gains computation - cost of acquisition relates back to date of transfer through will/family settlement to beneficiary. Determination of indexed cost of acquisition for residential property acquired through family settlement. Additional evidence not admissible before ITAT without following rules. Family settlement is not a transfer, cost of acquisition relates back to previous owner's acquisition. Family settlement need not be registered if recording prior arrangement. For capital gains, cost inflation index calculated from year property acquired by previous owner through registered deed. Family arrangement does not involve transfer, hence no capital gains tax. Calculation based on indexed cost from previous owner's acquisition date, even if will disregarded. Order of CIT(A) upheld, decided in favor of assessee.
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