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...
ITAT allowed the assessee's appeal, holding that the short-term capital loss of Rs.2,94,99,567 arising from sale of shares in the company (renamed during the year) was genuine trading loss and not a contrived adjustment entry. The Tribunal found the assessee to be a regular investor and trader in quoted and unquoted securities, noted supporting documentary evidence and prior trading activity, and rejected the AO's reliance on an external report characterising the scrip as penny stock without proper analysis of submitted records. Consequently the loss was held allowable for set-off against short-term capital gains and the additions made by the AO were deleted.
ITAT allowed the assessee's appeal, holding that the short-term capital loss of Rs.2,94,99,567 arising from sale of shares in the company (renamed during the year) was genuine trading loss and not a contrived adjustment entry. The Tribunal found the assessee to be a regular investor and trader in quoted and unquoted securities, noted supporting documentary evidence and prior trading activity, and rejected the AO's reliance on an external report characterising the scrip as penny stock without proper analysis of submitted records. Consequently the loss was held allowable for set-off against short-term capital gains and the additions made by the AO were deleted.
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