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...
Validity of transaction entered into by the applicant with the company in liquidation - It cannot be said that the applicant has entered into transaction of purchase of sale of the assets of the company without good faith or bona fide intention, more particularly, when the applicant has deposited the entire sale consideration with DENA bank with whom the property which was purchased by the applicant was mortgaged - HC
Validity of transaction entered into by the applicant with the company in liquidation - It cannot be said that the applicant has entered into transaction of purchase of sale of the assets of the company without good faith or bona fide intention, more particularly, when the applicant has deposited the entire sale consideration with DENA bank with whom the property which was purchased by the applicant was mortgaged - HC
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