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...
Section 87A rebate was held to depend on the rate of taxation, not merely the head of income. In a mixed-income case under the new tax regime, the Tribunal found that tax on capital gains chargeable at special rates is computed separately and the rebate cannot be set off against that component. The rebate was therefore confined to the tax attributable to income chargeable at normal rates, including business income and income from other sources. The appeal was partly allowed, and rebate under section 87A was denied against tax on special-rate capital gains.
Section 87A rebate was held to depend on the rate of taxation, not merely the head of income. In a mixed-income case under the new tax regime, the Tribunal found that tax on capital gains chargeable at special rates is computed separately and the rebate cannot be set off against that component. The rebate was therefore confined to the tax attributable to income chargeable at normal rates, including business income and income from other sources. The appeal was partly allowed, and rebate under section 87A was denied against tax on special-rate capital gains.
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