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...
Appeals to the High Court under the Black Money and Imposition of Tax Act, 2015 are classified as Tax Appeals rather than income-tax appeals. Rule 1(3A) applies to High Court appeals under any other enactment providing for the levy of tax, and section 19 of the Act provides for an appeal against a Tribunal order. An income-tax appeal may therefore be converted and registered as a Tax Appeal, subject to other objections.
Appeals to the High Court under the Black Money and Imposition of Tax Act, 2015 are classified as Tax Appeals rather than income-tax appeals. Rule 1(3A) applies to High Court appeals under any other enactment providing for the levy of tax, and section 19 of the Act provides for an appeal against a Tribunal order. An income-tax appeal may therefore be converted and registered as a Tax Appeal, subject to other objections.
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