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...
Power to arrest and GST - Section 69 which is akin to Section 19 of PMLA has inherent safeguards before affecting the arrest of accused persons. Thus, taking into account the totality of the facts and circumstances and in view of the judgment of The State of Gujrat Etc. [2023 (7) TMI 1008 - SUPREME COURT], no relief can be granted in the present petition to the petitioner. - HC
Power to arrest and GST - Section 69 which is akin to Section 19 of PMLA has inherent safeguards before affecting the arrest of accused persons. Thus, taking into account the totality of the facts and circumstances and in view of the judgment of The State of Gujrat Etc. [2023 (7) TMI 1008 - SUPREME COURT], no relief can be granted in the present petition to the petitioner. - HC
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