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...
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
Settlement application u/s 245C - Apportioning the undisclosed income in the hands of the petitioner and the Company - The High court examines the petitioner's disclosure and the basis for apportionment of income. It notes discrepancies and lack of clarity in the petitioner's submissions regarding the apportionment of unaccounted sales, expenditures, and income between the petitioner and the company. - The High court concurs with the Commission's finding that the petitioner did not disclose true and correct facts, violating the requirements of Section 245C(1).
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