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...
Declaration of Petitioner as a Wilful Defaulter under the Master Circular on Wilful Defaulters, 2015 - depriving the Petitioner from availing credit facilities for his present and prospective business enterprises - The High court found that the bank's reliance on a Forensic Audit Report, without independent verification or considering the petitioner's track record and the context of transactions, was inadequate to substantiate the declaration. - The court held that the bank failed to establish that the alleged acts of Wilful Default were "intentional, deliberate, and calculated," as required under the RBI's Master Circular.
Declaration of Petitioner as a Wilful Defaulter under the Master Circular on Wilful Defaulters, 2015 - depriving the Petitioner from availing credit facilities for his present and prospective business enterprises - The High court found that the bank's reliance on a Forensic Audit Report, without independent verification or considering the petitioner's track record and the context of transactions, was inadequate to substantiate the declaration. - The court held that the bank failed to establish that the alleged acts of Wilful Default were "intentional, deliberate, and calculated," as required under the RBI's Master Circular.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
