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...
Immediate instructions require all groups to prepare detailed, updated briefs for every matter pending before the Supreme Court, with cases graded for monitoring, including constitutional challenges and high-revenue matters. Files and synopses must be properly indexed and kept immediately retrievable so briefing can be provided to the Learned ASG at short notice. At least two to three senior officers in each group, including the Assistant Commissioner and the JC/ADC concerned, must familiarise themselves with case details to ensure effective briefing. The Deputy/Assistant Commissioner of each group is made responsible for monitoring strict compliance with these directions.
Immediate instructions require all groups to prepare detailed, updated briefs for every matter pending before the Supreme Court, with cases graded for monitoring, including constitutional challenges and high-revenue matters. Files and synopses must be properly indexed and kept immediately retrievable so briefing can be provided to the Learned ASG at short notice. At least two to three senior officers in each group, including the Assistant Commissioner and the JC/ADC concerned, must familiarise themselves with case details to ensure effective briefing. The Deputy/Assistant Commissioner of each group is made responsible for monitoring strict compliance with these directions.
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