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...
Revocation of cancellation of registration - failure to file the return for a continuous period of six months - In the present case along with the application, the petitioner had filed a statement to the effect that all the requisite returns have been filed and the dues are cleared and thus it was incumbent upon the Department to have verified the correctness of averments made in the application - now the Department has accepted that the returns were filed within time and no dues remain payable - the order cancelling the registration stands revoked from the date of filing of the application - HC
Revocation of cancellation of registration - failure to file the return for a continuous period of six months - In the present case along with the application, the petitioner had filed a statement to the effect that all the requisite returns have been filed and the dues are cleared and thus it was incumbent upon the Department to have verified the correctness of averments made in the application - now the Department has accepted that the returns were filed within time and no dues remain payable - the order cancelling the registration stands revoked from the date of filing of the application - HC
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