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...
SUBKA VISHWAS” [Legacy Dispute Resolution] Scheme Rules, 2019 - petitioner was unable to make payment due to technical glitch - The judgment reiterates the principle that a scheme must be followed strictly according to its terms and conditions. In this case, the "SUBKA VISHWAS" Scheme, being a complete code in itself, required adherence to specific time limits for filing and payment, which the petitioner failed to meet. The court emphasized that extending the time limit for compliance with the scheme’s provisions is beyond its jurisdiction under Article 226 of the Constitution of India. - HC
SUBKA VISHWAS” [Legacy Dispute Resolution] Scheme Rules, 2019 - petitioner was unable to make payment due to technical glitch - The judgment reiterates the principle that a scheme must be followed strictly according to its terms and conditions. In this case, the "SUBKA VISHWAS" Scheme, being a complete code in itself, required adherence to specific time limits for filing and payment, which the petitioner failed to meet. The court emphasized that extending the time limit for compliance with the scheme’s provisions is beyond its jurisdiction under Article 226 of the Constitution of India. - HC
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