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...
Service of notice and a subsequent order under the Act were treated as sufficient to set criminal proceedings in motion for wilful failure to deposit tax deducted at source under Section 276B. The High Court held that due service had been established, and the applicants could not resist prosecution by claiming ignorance when continued non-compliance after notice disclosed a prima facie case of wilful default. The objection of non-service was treated as a disputed factual issue for trial, not a ground for quashing in inherent jurisdiction. The fact that the offence was compoundable did not justify termination of the prosecution absent settlement. The applications for quashing were dismissed.
Service of notice and a subsequent order under the Act were treated as sufficient to set criminal proceedings in motion for wilful failure to deposit tax deducted at source under Section 276B. The High Court held that due service had been established, and the applicants could not resist prosecution by claiming ignorance when continued non-compliance after notice disclosed a prima facie case of wilful default. The objection of non-service was treated as a disputed factual issue for trial, not a ground for quashing in inherent jurisdiction. The fact that the offence was compoundable did not justify termination of the prosecution absent settlement. The applications for quashing were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
