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...
Order of transfer u/s 127 - transferring the case of the petitioner from Raipur to Delhi - Even if financial nexus is not palpable between the petitioner and the searched party, that by itself cannot take away the right of the Revenue to exercise its wide and sweeping powers u/s 127 of transferring a case in public interest i.e. for effective and expeditious completion of search, seizure and other operations. of premises. - HC
Order of transfer u/s 127 - transferring the case of the petitioner from Raipur to Delhi - Even if financial nexus is not palpable between the petitioner and the searched party, that by itself cannot take away the right of the Revenue to exercise its wide and sweeping powers u/s 127 of transferring a case in public interest i.e. for effective and expeditious completion of search, seizure and other operations. of premises. - HC
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