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...
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - it appears that the rejection is by a computer generated and/or a mechanical process by a remark that ‘show cause notice issued after 30th June, 2019’. Certainly there is no application of mind on the petitioner’s application on the provisions as made by clarificatory circular, as no reasons are furnished as to why the petitioner’s declaration cannot be entertained applying clause 2(viii) of the said Circular. - Application resumed - HC
Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019 - it appears that the rejection is by a computer generated and/or a mechanical process by a remark that ‘show cause notice issued after 30th June, 2019’. Certainly there is no application of mind on the petitioner’s application on the provisions as made by clarificatory circular, as no reasons are furnished as to why the petitioner’s declaration cannot be entertained applying clause 2(viii) of the said Circular. - Application resumed - HC
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