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...
Input tax credit - The assessee claimed input tax credit by depicting the true and correct facts. Though we have decided the case against the assessee, but it cannot be said that the dealer had claimed this input tax credit with a view to evade or avoid payment of tax. It is a plain and simple case of different interpretations of the provisions of law. - Minimum penalty of 10% imposed - HC
Input tax credit - The assessee claimed input tax credit by depicting the true and correct facts. Though we have decided the case against the assessee, but it cannot be said that the dealer had claimed this input tax credit with a view to evade or avoid payment of tax. It is a plain and simple case of different interpretations of the provisions of law. - Minimum penalty of 10% imposed - HC
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