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...
Availment of wrongful credit - bonafide mistake - The High Court observed that the mistake made by the appellants was inadvertent, and despite the acknowledgment of the error by the adjudicating authority, the demand was confirmed without providing any guidance or assistance to rectify the error. Considering previous legal precedents and the transitional phase of legislation, the court directed the authorities to enable the appellants to rectify the mistake and submit the correct form within a specified timeframe. Additionally, the Nodal Officer of IT Grievance Redressal Mechanism was directed to facilitate the filing process and provide options for manual rectification if necessary.
Availment of wrongful credit - bonafide mistake - The High Court observed that the mistake made by the appellants was inadvertent, and despite the acknowledgment of the error by the adjudicating authority, the demand was confirmed without providing any guidance or assistance to rectify the error. Considering previous legal precedents and the transitional phase of legislation, the court directed the authorities to enable the appellants to rectify the mistake and submit the correct form within a specified timeframe. Additionally, the Nodal Officer of IT Grievance Redressal Mechanism was directed to facilitate the filing process and provide options for manual rectification if necessary.
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