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...
Advance ruling was barred where the same input tax credit question was already pending in enforcement proceedings against the applicant. The Authority held that, under the proviso to section 98(2), an advance ruling cannot be admitted on a question already pending in proceedings under the Act in the applicant's case. Because the jurisdictional authority had already initiated action on admissibility of input tax credit for construction of the hotel building, and the applicant did not dispute that fact, the application was rejected without any ruling on the merits.
Advance ruling was barred where the same input tax credit question was already pending in enforcement proceedings against the applicant. The Authority held that, under the proviso to section 98(2), an advance ruling cannot be admitted on a question already pending in proceedings under the Act in the applicant's case. Because the jurisdictional authority had already initiated action on admissibility of input tax credit for construction of the hotel building, and the applicant did not dispute that fact, the application was rejected without any ruling on the merits.
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