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...
Requirement to comply with the pre-deposit of 12.5 per cent of the disputed tax along with the appeal - Here the appeal does not relate to imposing of tax for the relevant tax period or towards any tax liability or penalty imposed, but for a different purpose where no tax is quantified. Therefore, insisting on payment of 12.5 per cent. of difference of tax may not be proper. - HC
Requirement to comply with the pre-deposit of 12.5 per cent of the disputed tax along with the appeal - Here the appeal does not relate to imposing of tax for the relevant tax period or towards any tax liability or penalty imposed, but for a different purpose where no tax is quantified. Therefore, insisting on payment of 12.5 per cent. of difference of tax may not be proper. - HC
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