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...
The HC held that an orphan minor qualifies as an "individual" under the definition of "person" in Section 2(31) of the Income Tax Act. The contention that a minor must be capable of entering into a contract to be considered an individual was rejected. The Court found no basis to exclude an orphan minor from this classification, dismissing the argument that only minors with living parents qualify as individuals. The issue of whether the income earned by the petitioner is taxable was deemed inappropriate for determination in the present proceedings and left to the assessment authorities. The Court concluded that income of a minor, including an orphan, is not required to be clubbed with the guardian's income for tax purposes unless earned through the minor's own efforts, affirming the minor's independent tax identity.
The HC held that an orphan minor qualifies as an "individual" under the definition of "person" in Section 2(31) of the Income Tax Act. The contention that a minor must be capable of entering into a contract to be considered an individual was rejected. The Court found no basis to exclude an orphan minor from this classification, dismissing the argument that only minors with living parents qualify as individuals. The issue of whether the income earned by the petitioner is taxable was deemed inappropriate for determination in the present proceedings and left to the assessment authorities. The Court concluded that income of a minor, including an orphan, is not required to be clubbed with the guardian's income for tax purposes unless earned through the minor's own efforts, affirming the minor's independent tax identity.
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