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...
Delay in filing a GST appeal was treated as sufficiently explained where the order had been communicated to the Chartered Accountant, who failed to inform the taxpayer, and the mandatory pre-deposit was treated as substantial compliance with the appellate requirement. The note records that rejecting the appeal only on limitation, without considering the explanation, was viewed as a hyper-technical approach that could make the appellate remedy illusory, so the delay was condoned and the appeal was restored for hearing on merits. It also notes that the existing garnishee recovery, including freezing of bank accounts, was left in place until disposal of the appeal.
Delay in filing a GST appeal was treated as sufficiently explained where the order had been communicated to the Chartered Accountant, who failed to inform the taxpayer, and the mandatory pre-deposit was treated as substantial compliance with the appellate requirement. The note records that rejecting the appeal only on limitation, without considering the explanation, was viewed as a hyper-technical approach that could make the appellate remedy illusory, so the delay was condoned and the appeal was restored for hearing on merits. It also notes that the existing garnishee recovery, including freezing of bank accounts, was left in place until disposal of the appeal.
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