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 Section 50C's applicability extends beyond traditional ownership, encompassing various modes of property holding including leasehold rights. The term "held by an assessee" is interpreted broadly to include multiple legal arrangements such as leasehold, sub-leasehold, tenancy, and licensee interests. The court emphasized that the method of holding land does not create exceptions to tax provisions. The word 'transfer' under Section 50C must be construed with wide amplitude, covering all legally permissible transfer methods. Consequently, the court dismissed the appeal, affirming a comprehensive interpretation of property transfer and taxation principles.
HC held that Section 50C's applicability extends beyond traditional ownership, encompassing various modes of property holding including leasehold rights. The term "held by an assessee" is interpreted broadly to include multiple legal arrangements such as leasehold, sub-leasehold, tenancy, and licensee interests. The court emphasized that the method of holding land does not create exceptions to tax provisions. The word 'transfer' under Section 50C must be construed with wide amplitude, covering all legally permissible transfer methods. Consequently, the court dismissed the appeal, affirming a comprehensive interpretation of property transfer and taxation principles.
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