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 of encashed amount by the revenue - Direction to withdraw recovery proceedings by issuing a demand draft equivalent to the Bank Guarantee - circular dated 18.03.2020 - The Court notes the submissions of both parties regarding the inability to prefer an appeal due to the non-constitution of the appellate tribunal. - Referring to a circular, the Court acknowledges the issue of pending appellate processes due to the absence of the appellate tribunal. The Court directs the respondent to refund the encashed amount to the petitioner within one month from the date of the judgment. It further directs the petitioner to furnish a fresh bank guarantee within one week from the date of refund, valid for one year.
Refund claim of encashed amount by the revenue - Direction to withdraw recovery proceedings by issuing a demand draft equivalent to the Bank Guarantee - circular dated 18.03.2020 - The Court notes the submissions of both parties regarding the inability to prefer an appeal due to the non-constitution of the appellate tribunal. - Referring to a circular, the Court acknowledges the issue of pending appellate processes due to the absence of the appellate tribunal. The Court directs the respondent to refund the encashed amount to the petitioner within one month from the date of the judgment. It further directs the petitioner to furnish a fresh bank guarantee within one week from the date of refund, valid for one year.
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