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...
Seeks rectification or re-assessment - Claim of Exemption under Notification No.152/2009-customs - The High Court held that there is no reason to reject the application merely because it does not make reference to Section 149 or on the ground that the word rectification is not used therein - The writ petition is disposed of with the directive for the respondent to treat the petitioner's application as a rectification application and decide on it based on merits within a stipulated timeframe.
Seeks rectification or re-assessment - Claim of Exemption under Notification No.152/2009-customs - The High Court held that there is no reason to reject the application merely because it does not make reference to Section 149 or on the ground that the word rectification is not used therein - The writ petition is disposed of with the directive for the respondent to treat the petitioner's application as a rectification application and decide on it based on merits within a stipulated timeframe.
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