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...
Amendment of CST Registration Certificate - the application for amending the CST Registration Certificate has been made belatedly on 19.09.2020, nevertheless, there is no embargo under the aforesaid Rules to amend the date in the CST Registration Certificate - the records will be available with the respondents and therefore the respondents cannot reject the request of the petitioner merely stating that it is not possible to amend the Certificate at a later point of time. It was for the respondents to make suitable internal changes in their Web Portal to amend the Certificates of registration. - HC
Amendment of CST Registration Certificate - the application for amending the CST Registration Certificate has been made belatedly on 19.09.2020, nevertheless, there is no embargo under the aforesaid Rules to amend the date in the CST Registration Certificate - the records will be available with the respondents and therefore the respondents cannot reject the request of the petitioner merely stating that it is not possible to amend the Certificate at a later point of time. It was for the respondents to make suitable internal changes in their Web Portal to amend the Certificates of registration. - HC
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