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...
Pending appeals wherein, the IBC proceedings have been concluded by NCLT - Since the IBC proceedings have been concluded, these appeals shall stand infructuous accordingly, we dismiss these appeals as infructuous. Both the sides have liberty, in case of any amicable resolution is not arrived at between the appellant and the respondent, to approach to this tribunal to revive the present appeals and the same shall be decided on merit, if required. - AT
Pending appeals wherein, the IBC proceedings have been concluded by NCLT - Since the IBC proceedings have been concluded, these appeals shall stand infructuous accordingly, we dismiss these appeals as infructuous. Both the sides have liberty, in case of any amicable resolution is not arrived at between the appellant and the respondent, to approach to this tribunal to revive the present appeals and the same shall be decided on merit, if required. - AT
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