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...
Pre-Deposit - Adjustment of various deposits made by entities during the course of investigation - The appellant argued that since they were associated with these entities and deposits were made with No Objection Certificates, these amounts should be adjusted for the pre-deposit requirement. However, the High court upheld the decision of the CESTAT, emphasizing that Section 129E places the responsibility of pre-deposit solely on the appellant, and deposits made by other entities cannot be considered for this purpose. The court's decision was based on the clear language of the provision, and it found no reason to interfere with the CESTAT's order. Thus, the appeal was dismissed.
Pre-Deposit - Adjustment of various deposits made by entities during the course of investigation - The appellant argued that since they were associated with these entities and deposits were made with No Objection Certificates, these amounts should be adjusted for the pre-deposit requirement. However, the High court upheld the decision of the CESTAT, emphasizing that Section 129E places the responsibility of pre-deposit solely on the appellant, and deposits made by other entities cannot be considered for this purpose. The court's decision was based on the clear language of the provision, and it found no reason to interfere with the CESTAT's order. Thus, the appeal was dismissed.
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