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...
Recovery of demand - initiation of Garnishee proceedings - The assessment order and the demand does not remain merely a piece of paper, unless an assessee gets relief by a higher authority against the assessment order and demand arising from it, it is the statutory duty of the officer to see that the demand arising out of an adjudication order is being realised. Further, adjudication order in question out of which the demand in question arises is an appealable order and till date petitioner has not availed any remedy under the statute by way of filing appeal against the same. - Petition dismissed - HC
Recovery of demand - initiation of Garnishee proceedings - The assessment order and the demand does not remain merely a piece of paper, unless an assessee gets relief by a higher authority against the assessment order and demand arising from it, it is the statutory duty of the officer to see that the demand arising out of an adjudication order is being realised. Further, adjudication order in question out of which the demand in question arises is an appealable order and till date petitioner has not availed any remedy under the statute by way of filing appeal against the same. - Petition dismissed - HC
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