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...
Stay of collection of the disputed tax - Since it is not disputed by the learned Special Counsel for Commercial Tax that petitioner had already deposited 2/3rds of the disputed tax, and since admittedly appeal filed by petitioner before the Telangana VAT Tribunal is still pending and if the balance tax is also permitted to be receoved, the very appeal would become infructuous.
Stay of collection of the disputed tax - Since it is not disputed by the learned Special Counsel for Commercial Tax that petitioner had already deposited 2/3rds of the disputed tax, and since admittedly appeal filed by petitioner before the Telangana VAT Tribunal is still pending and if the balance tax is also permitted to be receoved, the very appeal would become infructuous.
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