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...
Interim access to frozen funds under the PMLA may be permitted for essential employee salaries and statutory dues where the liabilities are genuine, the subsidiary prima facie owes funds to its holding company, and safeguards preserve the attached assets. Verified payments of TDS and GST avoid compelled statutory defaults while benefiting the Central Government. Limited access was permitted for verified outstanding salaries and statutory dues, subject to submission of payment details, verification and bank-authorisation safeguards, without addressing the merits of the pending appeals.
Interim access to frozen funds under the PMLA may be permitted for essential employee salaries and statutory dues where the liabilities are genuine, the subsidiary prima facie owes funds to its holding company, and safeguards preserve the attached assets. Verified payments of TDS and GST avoid compelled statutory defaults while benefiting the Central Government. Limited access was permitted for verified outstanding salaries and statutory dues, subject to submission of payment details, verification and bank-authorisation safeguards, without addressing the merits of the pending appeals.
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