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...
Time Limitation for filing refund claim - Impact of COVID-19 Pandemic - The High Court, considering the exceptional circumstances, interpreted the limitation period flexibly and referred to legislative provisions and notifications extending the period. Consequently, the court set aside the impugned order and remitted the case for reconsideration, directing the respondent to review the petitioner's refund claim in light of the extended limitation period, with a mandate for expeditious resolution.
Time Limitation for filing refund claim - Impact of COVID-19 Pandemic - The High Court, considering the exceptional circumstances, interpreted the limitation period flexibly and referred to legislative provisions and notifications extending the period. Consequently, the court set aside the impugned order and remitted the case for reconsideration, directing the respondent to review the petitioner's refund claim in light of the extended limitation period, with a mandate for expeditious resolution.
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