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...
Provisional Attachment of Bank Accounts of petitioner - availment of wrongful input tax credit - A detailed circumstance which are pointed out by an respondent / Revenue authority in its affidavit-in-reply as mentioned hereinbefore including the detail show-cause notice and the steps which are taken u/s 74 of the Act, as indicated above, i.e. on 15.03.2023 as well as 16.03.2023, exercising extraordinary equitable jurisdiction is refrained. - HC
Provisional Attachment of Bank Accounts of petitioner - availment of wrongful input tax credit - A detailed circumstance which are pointed out by an respondent / Revenue authority in its affidavit-in-reply as mentioned hereinbefore including the detail show-cause notice and the steps which are taken u/s 74 of the Act, as indicated above, i.e. on 15.03.2023 as well as 16.03.2023, exercising extraordinary equitable jurisdiction is refrained. - HC
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