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...
Overlapping demand confirmed u/s 63 and Section 74 of TNGST Act for same assessment years cannot be challenged. However, petitioner's failure to reply to show cause notices preceding impugned orders necessitates remand for fresh orders on merits in accordance with law by respondents after detailed consideration. Petitions disposed off through remand.
Overlapping demand confirmed u/s 63 and Section 74 of TNGST Act for same assessment years cannot be challenged. However, petitioner's failure to reply to show cause notices preceding impugned orders necessitates remand for fresh orders on merits in accordance with law by respondents after detailed consideration. Petitions disposed off through remand.
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