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...
A writ petition challenging three appellate orders was found not maintainable because an efficacious statutory appeal lay before the Tribunal under the Act. The challenge centred on an alleged insistence on a notarized sale agreement, later said to have been produced, but the court held that this and the related issues required appreciation of facts and law and were therefore for the appellate forum. On that basis, writ jurisdiction was declined and the petitioners were left to pursue the statutory appellate remedy.
A writ petition challenging three appellate orders was found not maintainable because an efficacious statutory appeal lay before the Tribunal under the Act. The challenge centred on an alleged insistence on a notarized sale agreement, later said to have been produced, but the court held that this and the related issues required appreciation of facts and law and were therefore for the appellate forum. On that basis, writ jurisdiction was declined and the petitioners were left to pursue the statutory appellate remedy.
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