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...
Automatic abatement of settlement application if no final order is passed by the Settlement Commission - though the petitioners to some extent were also responsible for the delay caused in completion of the proceedings, but it cannot be said that the petitioners alone were guilty of causing such delay because the department was also contributory in prolonging the proceedings for one reason or the other - matter restored - HC
Automatic abatement of settlement application if no final order is passed by the Settlement Commission - though the petitioners to some extent were also responsible for the delay caused in completion of the proceedings, but it cannot be said that the petitioners alone were guilty of causing such delay because the department was also contributory in prolonging the proceedings for one reason or the other - matter restored - HC
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