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...
Maintainability of appeal - appeal dismissed arising out of stay order of appellate authority - the order of the Tribunal is ex facie erroneous, inasmuch as, it refuses even to consider prima facie case while deciding the stay application, thus, there are no hesitation in holding that the order of Tribunal is clearly contrary to the settled law and is liable to be set aside.- HC
Maintainability of appeal - appeal dismissed arising out of stay order of appellate authority - the order of the Tribunal is ex facie erroneous, inasmuch as, it refuses even to consider prima facie case while deciding the stay application, thus, there are no hesitation in holding that the order of Tribunal is clearly contrary to the settled law and is liable to be set aside.- HC
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