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...
Inordinate delay of more than 2100 days in filing revisions was not condoned because the revisionists offered no plausible explanation, had absconded after conviction, and had shown disregard for the court process. Despite that, the High Court set aside the non-speaking appellate judgments because the criminal appeals had been decided in the appellants' absence without appointment of amicus curiae and without the required scrutiny of the record and trial court reasoning. Applying the rule in Bani Singh and related authorities, the Court held that such defective disposal could not stand and revived the appeals for fresh hearing on merits, subject to deposit of part of the fine and payment of costs.
Inordinate delay of more than 2100 days in filing revisions was not condoned because the revisionists offered no plausible explanation, had absconded after conviction, and had shown disregard for the court process. Despite that, the High Court set aside the non-speaking appellate judgments because the criminal appeals had been decided in the appellants' absence without appointment of amicus curiae and without the required scrutiny of the record and trial court reasoning. Applying the rule in Bani Singh and related authorities, the Court held that such defective disposal could not stand and revived the appeals for fresh hearing on merits, subject to deposit of part of the fine and payment of costs.
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