https://www.taxtmi.com/caselaws?id=354566 A call option termination linked to foreign group arrangements was treated as an international transaction capable of transfer pricing adjustment because the statutory definition of transaction is broad enough to cover concerted arrangements, and the transferred right was characterised as a capital asset; the resulting income was therefore directed to be assessed as capital gains rather than business income. Depreciation on goodwill acquired in a business transfer was remanded for fresh examination. Disallowance under section 14A read with Rule 8D was deleted because no exempt income was earned in the relevant year. Club membership expenditure was treated partly as capital/revenue on the facts and partly remanded for verification. en-us Tue, 23 Jan 2018 00:00:00 +0530 Wed, 31 Jan 2018 18:02:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354566 A call option termination linked to foreign group arrangements was treated as an international transaction capable of transfer pricing adjustment because the statutory definition of transaction is broad enough to cover concerted arrangements, and the transferred right was characterised as a capital asset; the resulting income was therefore directed to be assessed as capital gains rather than business income. Depreciation on goodwill acquired in a business transfer was remanded for fresh examination. Disallowance under section 14A read with Rule 8D was deleted because no exempt income was earned in the relevant year. Club membership expenditure was treated partly as capital/revenue on the facts and partly remanded for verification. Case-Laws Income Tax Tue, 23 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354566