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...
Benefits under the VsV Act [Vivad Se Vishwas Act] denied - The court directed the respondents to accept the petitioner's declaration under the VsV Act, subject to the petitioner paying the balance amount - The decision acknowledges the petitioner's efforts to comply with the VsV Act and addresses technical glitches and errors by the respondents, reflecting the VsV Act's objective to reduce tax litigation and generate revenue efficiently. - HC
Benefits under the VsV Act [Vivad Se Vishwas Act] denied - The court directed the respondents to accept the petitioner's declaration under the VsV Act, subject to the petitioner paying the balance amount - The decision acknowledges the petitioner's efforts to comply with the VsV Act and addresses technical glitches and errors by the respondents, reflecting the VsV Act's objective to reduce tax litigation and generate revenue efficiently. - HC
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