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...
Power u/s 83 as well as under Section 5(3) off KGST Act - designation of proper officer in terms of Sections 83(1) and 5(3) of the Act be adjudicated upon - Power to attach bank accounts - Interim Relief granted - the challenge as regards delegation under Section 83 of the Act by the Commissioner to other person would remain an academic question which need not be adjudicated in the present case and may be dealt with in an appropriate case. - HC
Power u/s 83 as well as under Section 5(3) off KGST Act - designation of proper officer in terms of Sections 83(1) and 5(3) of the Act be adjudicated upon - Power to attach bank accounts - Interim Relief granted - the challenge as regards delegation under Section 83 of the Act by the Commissioner to other person would remain an academic question which need not be adjudicated in the present case and may be dealt with in an appropriate case. - HC
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