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...
Validity of assessment order - classification of oil coolers as heat exchangers - The High court observed that the petitioner's main grievance was the disregard of the Chartered Engineer's certificate. However, the court determined that this contention could be raised in appellate proceedings, as the overall facts and circumstances did not justify interference under Article 226 of the Constitution. - The court disposed of the writ petition by permitting the petitioner to file a statutory appeal before the appellate authority within three weeks.
Validity of assessment order - classification of oil coolers as heat exchangers - The High court observed that the petitioner's main grievance was the disregard of the Chartered Engineer's certificate. However, the court determined that this contention could be raised in appellate proceedings, as the overall facts and circumstances did not justify interference under Article 226 of the Constitution. - The court disposed of the writ petition by permitting the petitioner to file a statutory appeal before the appellate authority within three weeks.
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