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...
Condonation of delay in claiming refund based on Tax Deducted at Source [TDS] - As the petitioner is being permitted to file revised returns on condonation of delay, if there is any occasion for the respondents to initiate proceedings u/s 143[2] for framing of assessment u/s 143[3] petitioner must be precluded from raising the defence of limitation. - HC
Condonation of delay in claiming refund based on Tax Deducted at Source [TDS] - As the petitioner is being permitted to file revised returns on condonation of delay, if there is any occasion for the respondents to initiate proceedings u/s 143[2] for framing of assessment u/s 143[3] petitioner must be precluded from raising the defence of limitation. - HC
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