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...
SVLDRS - Rejection of declaration - It is relevant to note that the respondents had never disputed or doubted the statements submitted by the petitioner. On the contrary, it is apparent that the respondents had accepted the said statements - The impugned order rejecting the petitioner’s declaration on the ground that “investigation has not been concluded and hence the demand has not been estimated or concluded on or before the stipulated date” is unsustainable. - HC
SVLDRS - Rejection of declaration - It is relevant to note that the respondents had never disputed or doubted the statements submitted by the petitioner. On the contrary, it is apparent that the respondents had accepted the said statements - The impugned order rejecting the petitioner’s declaration on the ground that “investigation has not been concluded and hence the demand has not been estimated or concluded on or before the stipulated date” is unsustainable. - HC
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