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...
Rejection of petitioner’s application for amendment of the registration, namely, change in address of the petitioner - The court addressed the suspension of the petitioner's registration and the issuance of a show cause notice for cancellation. It noted that these actions were premature and arbitrary since they were based on issues that were subject to the pending amendment application. The court directed the respondent to decide on the pending application within a specified timeframe and allowed the petitioner to file a reply to the show cause notice, reserving their right to challenge any adverse decisions.
Rejection of petitioner’s application for amendment of the registration, namely, change in address of the petitioner - The court addressed the suspension of the petitioner's registration and the issuance of a show cause notice for cancellation. It noted that these actions were premature and arbitrary since they were based on issues that were subject to the pending amendment application. The court directed the respondent to decide on the pending application within a specified timeframe and allowed the petitioner to file a reply to the show cause notice, reserving their right to challenge any adverse decisions.
Note: It is a system-generated summary and is for quick reference only.
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