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...
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
Wavier Pre-deposit - alternate and efficacious remedy - no explanation as to why petitioners chose to remain absent before the Adjudicating Authority or to avail of opportunity for cross-examination - nothing demonstrated as to why the petitioners cannot avail the alternate remedy of appeal and neither pleaded nor elaborated that pre-deposit constitutes a hardship, not a fit case to ignore the mandate of Section 129E
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
