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...
Stay of demand - guideline for stay of demand on payment of 20% of the disputed demand (earlier 15%) till the final disposal of the first appeal - Adjustment of future refunds - The condition of the order is set aside to the extent it puts a condition of adjustment of future demands arising to the writ applicants. There shall be unconditional stay of demand against the application filed by the writ applicants till the final disposal of the appeal pending before the ITAT - HC
Stay of demand - guideline for stay of demand on payment of 20% of the disputed demand (earlier 15%) till the final disposal of the first appeal - Adjustment of future refunds - The condition of the order is set aside to the extent it puts a condition of adjustment of future demands arising to the writ applicants. There shall be unconditional stay of demand against the application filed by the writ applicants till the final disposal of the appeal pending before the ITAT - HC
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