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...
Presence of Advocate during Enquiry/interrogation as a matter of right - in the earlier judgements of the High Court’s, the presence of advocate was allowed on the basis of apprehensions that there may be some coercive attempt may be made against the petitioner. Since in the present case there is no such apprehension, the presence of advocate cannot be allowed as a matter of right during investigation. - HC
Presence of Advocate during Enquiry/interrogation as a matter of right - in the earlier judgements of the High Court’s, the presence of advocate was allowed on the basis of apprehensions that there may be some coercive attempt may be made against the petitioner. Since in the present case there is no such apprehension, the presence of advocate cannot be allowed as a matter of right during investigation. - HC
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