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...
Levy of Entry tax - tractor trolly - ‘motor vehicle’ - the trolly cannot exist as a motor vehicle independent of the ‘tractor’ to which it is supposed to be attached. - since the tractor itself is excluded from the definition of ‘motor vehicle’ under Section 2(h) of the OET Act, the question of bringing ‘trolly’ as a stand-alone vehicle within the purview of that definition does not arise. - HC
Levy of Entry tax - tractor trolly - ‘motor vehicle’ - the trolly cannot exist as a motor vehicle independent of the ‘tractor’ to which it is supposed to be attached. - since the tractor itself is excluded from the definition of ‘motor vehicle’ under Section 2(h) of the OET Act, the question of bringing ‘trolly’ as a stand-alone vehicle within the purview of that definition does not arise. - HC
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