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...
Validity of detention order - proceedings under COFEPOSA - There is unexplained delay in passing the detention order of approximately 8 months - Further once the order of detention was passed a representation was likely to be made, hence, the same should have been decided within the shortest period of time - period of period of 11 working days are inordinate delay - HC
Validity of detention order - proceedings under COFEPOSA - There is unexplained delay in passing the detention order of approximately 8 months - Further once the order of detention was passed a representation was likely to be made, hence, the same should have been decided within the shortest period of time - period of period of 11 working days are inordinate delay - HC
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