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 derived from production and sale of hybrid seeds qualified as agricultural income within s.10(1) because the appellant, although not directly tilling land, exercised supervision, technical guidance, contractual control and bore risk and expense of cultivation carried out by farmers to produce parent and hybrid seeds. The Court concluded the operations constituted agricultural activity carried out through contractors, establishing a direct nexus with land. Accordingly, the HC allowed the appellant's appeal, treating the receipts as exempt agricultural income and reversing the characterization that disallowed exemption, while recognising the legitimacy of production-by-contract and the appellant's effective control over cultivation.
HC held that income derived from production and sale of hybrid seeds qualified as agricultural income within s.10(1) because the appellant, although not directly tilling land, exercised supervision, technical guidance, contractual control and bore risk and expense of cultivation carried out by farmers to produce parent and hybrid seeds. The Court concluded the operations constituted agricultural activity carried out through contractors, establishing a direct nexus with land. Accordingly, the HC allowed the appellant's appeal, treating the receipts as exempt agricultural income and reversing the characterization that disallowed exemption, while recognising the legitimacy of production-by-contract and the appellant's effective control over cultivation.
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