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...
Auction of property by the Department to recover tax - Income Tax Department cannot put the entire matter in cold storage and keep the purchaser running from pillar to post to recover the moneies paid by them towards the purchase price along with interest. It is not clear as to why the possession of the property has not been handed over to the purchaser / appellants - Refund of money deposited by the Auction purchaser with interest allowed - HC
Auction of property by the Department to recover tax - Income Tax Department cannot put the entire matter in cold storage and keep the purchaser running from pillar to post to recover the moneies paid by them towards the purchase price along with interest. It is not clear as to why the possession of the property has not been handed over to the purchaser / appellants - Refund of money deposited by the Auction purchaser with interest allowed - HC
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