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...
Expiry of an insolvency professional's authorisation on attaining 70 years did not end an ongoing assignment, because Regulation 7A's proviso preserved assignments already in progress when authorisation expired; the Bankruptcy Trustee was allowed to continue and complete the work. The challenge to removal on that ground was rejected. The challenge to extension of the liquidation period was also dismissed because the extension had already expired by the time the appeal was heard, and interference would have been academic; the decision to seek extension had been treated as valid. Both appeals were dismissed.
Expiry of an insolvency professional's authorisation on attaining 70 years did not end an ongoing assignment, because Regulation 7A's proviso preserved assignments already in progress when authorisation expired; the Bankruptcy Trustee was allowed to continue and complete the work. The challenge to removal on that ground was rejected. The challenge to extension of the liquidation period was also dismissed because the extension had already expired by the time the appeal was heard, and interference would have been academic; the decision to seek extension had been treated as valid. Both appeals were dismissed.
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