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...
Recovery of redemption fine from the petitioner - petitioner was not party to the SCN - In absence of any proposal in the show cause notice for imposition of fine in lieu of confiscation relatable to the petitioner and in absence of any directions contained in the order-inoriginal that such fine would be borne by the petitioner, it was simply not open for the department to seek recovery thereof from the petitioner- HC
Recovery of redemption fine from the petitioner - petitioner was not party to the SCN - In absence of any proposal in the show cause notice for imposition of fine in lieu of confiscation relatable to the petitioner and in absence of any directions contained in the order-inoriginal that such fine would be borne by the petitioner, it was simply not open for the department to seek recovery thereof from the petitioner- HC
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