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...
HC held that income tax exemption under Section 10(26) for Scheduled Tribes is only applicable when income accrues in specified areas under Sixth Schedule. The interest on compensation was deemed to have accrued in North Lakhimpur, Assam, which does not fall within Sixth Schedule areas. Railway Tribunal's orders directing NF Railway to refund tax deducted at source were set aside, as mere tribal status from Arunachal Pradesh was insufficient grounds for exemption. The geographical location of income accrual, not tribal status alone, determines eligibility for tax exemption under Section 10(26).
HC held that income tax exemption under Section 10(26) for Scheduled Tribes is only applicable when income accrues in specified areas under Sixth Schedule. The interest on compensation was deemed to have accrued in North Lakhimpur, Assam, which does not fall within Sixth Schedule areas. Railway Tribunal's orders directing NF Railway to refund tax deducted at source were set aside, as mere tribal status from Arunachal Pradesh was insufficient grounds for exemption. The geographical location of income accrual, not tribal status alone, determines eligibility for tax exemption under Section 10(26).
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