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...
Withholding of Refund - Appeal pending before the Apex Court - Tribunal ordered refund - The question of asking the Commissioner to remain personally present explaining why contempt proceedings should not be initiated, simply did not arise. We have serious doubt whether the Tribunal has the power to summon personal presence of a Government authority. - HC
Withholding of Refund - Appeal pending before the Apex Court - Tribunal ordered refund - The question of asking the Commissioner to remain personally present explaining why contempt proceedings should not be initiated, simply did not arise. We have serious doubt whether the Tribunal has the power to summon personal presence of a Government authority. - HC
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