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...
Extension of time for disposing pending rectification applications by Interim Board for Settlement - It is proposed to substitute Section 245(9)(iv) so as to provide that where the time-limit for amending any order or filing of rectification application under section 245D(6B) expires on or after the 1st February, 2021, but before the 1st February, 2022, such time-limit shall be extended to 30th September, 2023. This amendment will take effect retrospectively from 1st February, 2021.
Extension of time for disposing pending rectification applications by Interim Board for Settlement - It is proposed to substitute Section 245(9)(iv) so as to provide that where the time-limit for amending any order or filing of rectification application under section 245D(6B) expires on or after the 1st February, 2021, but before the 1st February, 2022, such time-limit shall be extended to 30th September, 2023. This amendment will take effect retrospectively from 1st February, 2021.
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