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...
Restoration of name of company in the ROC - company under litigation - Pending litigation in itself has been judicially recognized as a ‘just’ ground for restoration of a Company struck off the ROC - the matter was to be approached from a broader perspective keeping in view the interests of various stakeholders and larger social interest which can be better subserved by restoring a Company struck off for mere statutory non-compliances, which is admittedly not a Shell Company
Restoration of name of company in the ROC - company under litigation - Pending litigation in itself has been judicially recognized as a ‘just’ ground for restoration of a Company struck off the ROC - the matter was to be approached from a broader perspective keeping in view the interests of various stakeholders and larger social interest which can be better subserved by restoring a Company struck off for mere statutory non-compliances, which is admittedly not a Shell Company
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