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...
Issuance of separate SCN with respect to same search and seizure operation - two proceedings by two authorities of GST department - it is unbelievable that two (not one), authority of the Mobile Squad of Commercial Tax Department chose to act with negligence - the officers are accountable for their acts. Therefore, let this order be communicated to the Commissioner Commercial Tax UP to look into the matter, call for explanation and take appropriate action commensurate to the misconduct, if any, that may be found committed by the erring officers and to take consequential and corrective action to avoid such occurrences, in future - HC
Issuance of separate SCN with respect to same search and seizure operation - two proceedings by two authorities of GST department - it is unbelievable that two (not one), authority of the Mobile Squad of Commercial Tax Department chose to act with negligence - the officers are accountable for their acts. Therefore, let this order be communicated to the Commissioner Commercial Tax UP to look into the matter, call for explanation and take appropriate action commensurate to the misconduct, if any, that may be found committed by the erring officers and to take consequential and corrective action to avoid such occurrences, in future - HC
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