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...
Refund adjustment against a disputed tax demand was held unsustainable during pendency of the first appeal where the taxpayer had already deposited more than 50% of the demand. The Court found that coercive recovery, including garnishee action and adjustment of refunds for other assessment years, could not continue until disposal of the appeal. The revenue was directed to release the recovered amount with interest under section 244A, and no further coercive steps were permitted for the relevant assessment year pending appellate disposal.
Refund adjustment against a disputed tax demand was held unsustainable during pendency of the first appeal where the taxpayer had already deposited more than 50% of the demand. The Court found that coercive recovery, including garnishee action and adjustment of refunds for other assessment years, could not continue until disposal of the appeal. The revenue was directed to release the recovered amount with interest under section 244A, and no further coercive steps were permitted for the relevant assessment year pending appellate disposal.
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