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...
Compounding of offences for delayed remittance of tax deducted at source under Sections 276B and 278B was restored where stipulated charges were not paid within the prescribed period but were subsequently deposited in full. Financial difficulties and the company's subsequent liquidation were treated as bona fide reasons for the delay. The High Court extended the payment period up to the actual date of deposit, set aside rejection of the compounding applications, and made the earlier compounding order effective until that date. Restoration remained subject to additional costs payable to the Department, which could seek withdrawal of the deposited compounding charges. A second compounding application was unnecessary.
Compounding of offences for delayed remittance of tax deducted at source under Sections 276B and 278B was restored where stipulated charges were not paid within the prescribed period but were subsequently deposited in full. Financial difficulties and the company's subsequent liquidation were treated as bona fide reasons for the delay. The High Court extended the payment period up to the actual date of deposit, set aside rejection of the compounding applications, and made the earlier compounding order effective until that date. Restoration remained subject to additional costs payable to the Department, which could seek withdrawal of the deposited compounding charges. A second compounding application was unnecessary.
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