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...
Vicarious liability of partner of the firm - separate identity of partnership firm - merely the petitioner running a firm, but it is not a legal entity and it cannot be placed on par with the companies which is registered under the Companies Act - If an offence committed by the firm, is also an offence committed by the partners, it cannot be bifurcated as partners and the firm - the Trial Court, rightly took the cognizance against the petitioner for the offence punishable under section 240(3) of Companies Act. - HC
Vicarious liability of partner of the firm - separate identity of partnership firm - merely the petitioner running a firm, but it is not a legal entity and it cannot be placed on par with the companies which is registered under the Companies Act - If an offence committed by the firm, is also an offence committed by the partners, it cannot be bifurcated as partners and the firm - the Trial Court, rightly took the cognizance against the petitioner for the offence punishable under section 240(3) of Companies Act. - HC
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