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...
Finalization of the provisional assessment - The High Court emphasized the need for expeditious conclusion of internal processes, particularly when all required documents were submitted by the petitioners. The failure to issue specific communications to the petitioners regarding any further requirements or compliances, coupled with the decision not to finalize the bills of entries, amounted to arbitrariness and abdication of duties by the concerned officers. In light of the above, the High Court directed the respondent to finalize the bills of entries within four weeks from the date of the judgment.
Finalization of the provisional assessment - The High Court emphasized the need for expeditious conclusion of internal processes, particularly when all required documents were submitted by the petitioners. The failure to issue specific communications to the petitioners regarding any further requirements or compliances, coupled with the decision not to finalize the bills of entries, amounted to arbitrariness and abdication of duties by the concerned officers. In light of the above, the High Court directed the respondent to finalize the bills of entries within four weeks from the date of the judgment.
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