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...
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS) - The cut-off date of 30.06.2019 is applicable only in the eventualities which are covered under Rules 3(a) and 3(c) - The cut-off date of 30.06.2019 is not applicable for the cases which are covered under Rules 3(b) & 3(c). This cut-off date has been clarified in a Circular - by no stretch of imagination it can be said that paragraph Nos.vii and viii of the Circular is said to be in violation of the Scheme, 2019.
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 (SVLDRS) - The cut-off date of 30.06.2019 is applicable only in the eventualities which are covered under Rules 3(a) and 3(c) - The cut-off date of 30.06.2019 is not applicable for the cases which are covered under Rules 3(b) & 3(c). This cut-off date has been clarified in a Circular - by no stretch of imagination it can be said that paragraph Nos.vii and viii of the Circular is said to be in violation of the Scheme, 2019.
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