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...
Benefit of Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - refusal to accept the manual returns filed - The requirement of electronic filing is further evidenced by the provisions of the SVLDR Scheme, wherein also, it is specified that the declaration under Section 125 of the Act must be filed electronically. Thus, with the advent of information technology and its advancement, the shift from manual filing to electronic filing serves a salutary purpose and this Court cannot in exercise of its jurisdiction under Article 226 of the Constitution of India interfere with such seamless administration under the taxing statutes - HC
Benefit of Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - refusal to accept the manual returns filed - The requirement of electronic filing is further evidenced by the provisions of the SVLDR Scheme, wherein also, it is specified that the declaration under Section 125 of the Act must be filed electronically. Thus, with the advent of information technology and its advancement, the shift from manual filing to electronic filing serves a salutary purpose and this Court cannot in exercise of its jurisdiction under Article 226 of the Constitution of India interfere with such seamless administration under the taxing statutes - HC
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