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...
Reduction of cost imposed on Income Tax officers - they have acted arbitrarily, illegally without jurisdiction, caused harrassment to the petitioner and abused power conferred under the Act, 196 - corrective steps being taken by the respondent-department to improve its working - we reduce the cost from Rs.50 lacs to Rs.5 lacs with the consent of learned counsel for the petitioner and accordingly modify our judgment dated 11.08.2022 in respect of cost only. - HC
Reduction of cost imposed on Income Tax officers - they have acted arbitrarily, illegally without jurisdiction, caused harrassment to the petitioner and abused power conferred under the Act, 196 - corrective steps being taken by the respondent-department to improve its working - we reduce the cost from Rs.50 lacs to Rs.5 lacs with the consent of learned counsel for the petitioner and accordingly modify our judgment dated 11.08.2022 in respect of cost only. - HC
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