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HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
HC held that assessment orders passed under Section 62 for non-filing of returns stood deemed withdrawn once the taxpayers later filed the returns for the relevant periods along with tax, interest and late fee. The statutory consequence under Section 62(2) barred further recovery on the basis of those assessment orders. Any amount already recovered under the withdrawn orders was directed to be adjusted against the taxpayers' outstanding tax dues.
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