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...
Vivad se Vishwas Scheme - Extension of the last date for payment of tax sought to be applied for filing new application - No such press release or notification was issued by the CBDT in the case of the latter. Secondly and fundamentally, the two are different. In the case of the former, the declarations were filed within time i.e., before the last date of 31.03.2021. Thereafter the amount to be paid by the declarants were adjudicated by the designated authority whereafter the payments were to be made; it is for the payment of the determined amount that the time line was extended as above. It cannot be equated with filing of declaration beyond the last date. - HC
Vivad se Vishwas Scheme - Extension of the last date for payment of tax sought to be applied for filing new application - No such press release or notification was issued by the CBDT in the case of the latter. Secondly and fundamentally, the two are different. In the case of the former, the declarations were filed within time i.e., before the last date of 31.03.2021. Thereafter the amount to be paid by the declarants were adjudicated by the designated authority whereafter the payments were to be made; it is for the payment of the determined amount that the time line was extended as above. It cannot be equated with filing of declaration beyond the last date. - HC
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