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...
Violation under FERA - charge u/s. 56 of FERA - Company being in Liquidation - Whether the charge against the Company can be framed through the petitioner? - Petitioner had resigned from the Company in the year 1993, that is, much before the alleged transaction that took place in 1997. - The court concludes that the trial court erred in framing the charge against the company through the petitioner. It orders modification of the impugned order to reflect that the charge against the company should be through the Provisional Liquidator. However, it clarifies that the charges framed against the petitioner in his individual capacity remain unaffected.
Violation under FERA - charge u/s. 56 of FERA - Company being in Liquidation - Whether the charge against the Company can be framed through the petitioner? - Petitioner had resigned from the Company in the year 1993, that is, much before the alleged transaction that took place in 1997. - The court concludes that the trial court erred in framing the charge against the company through the petitioner. It orders modification of the impugned order to reflect that the charge against the company should be through the Provisional Liquidator. However, it clarifies that the charges framed against the petitioner in his individual capacity remain unaffected.
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