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...
Sabka Vishwas (Legacy Dispute Resolution) Scheme - payment after the cut of date - he petitioners have paid the amount from its bank account on 30.06.2020. The petitioners are not at fault for amount not transferred in the account of the Government by the bank on the same day on 30.06.2020 - for all intent and purpose, it cannot be said that the petitioners have failed to deposit the amount as required under Rule 7 of the Rules. - HC
Sabka Vishwas (Legacy Dispute Resolution) Scheme - payment after the cut of date - he petitioners have paid the amount from its bank account on 30.06.2020. The petitioners are not at fault for amount not transferred in the account of the Government by the bank on the same day on 30.06.2020 - for all intent and purpose, it cannot be said that the petitioners have failed to deposit the amount as required under Rule 7 of the Rules. - HC
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