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...
Validity of Revision u/s 263 - non mentioning computer generated DIN - Non-est order - Circular categorically mentions that subsequent to 01/10/2019, the computer generated DIN not only be allotted but be duly quoted in the body of the communication itself. - Neither the reasons nor the statement in the prescribed format is to be found in the order passed u/s 263 of the Act, spelling out the particular category of exception that prevented allotting the DIN on that day. It is yet another violation. - such an order shall be treated to have never been issued and, therefore, shall not take any affect. - AT
Validity of Revision u/s 263 - non mentioning computer generated DIN - Non-est order - Circular categorically mentions that subsequent to 01/10/2019, the computer generated DIN not only be allotted but be duly quoted in the body of the communication itself. - Neither the reasons nor the statement in the prescribed format is to be found in the order passed u/s 263 of the Act, spelling out the particular category of exception that prevented allotting the DIN on that day. It is yet another violation. - such an order shall be treated to have never been issued and, therefore, shall not take any affect. - AT
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