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...
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
Refund claim - rejection on the ground of time limitation - The High Court noted the applicability of the Notification dated 05.07.2022, which explicitly excluded the relevant period for the computation of the limitation period. As the petitioner's case fell within this excluded period, the rejection of the refund applications solely on the ground of limitation was deemed unsustainable. - The HC restored the refund applications to the record of the Assessing Authority.
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