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...
Guidelines clarify recovery proceedings in cases where first appeal is disposed but taxpayer cannot file further appeal due to non-operation of Appellate Tribunal. Taxpayers can make pre-deposit payment through Electronic Liability Register to avail stay on recovery. Undertaking to file appeal when Tribunal operationalizes is required. Amounts paid inadvertently through DRC-03 can be adjusted towards pre-deposit by filing DRC-03A application. Till DRC-03A functionality is available, intimation to proper officer suffices for stay on recovery. Failure to file appeal after Tribunal's operation will lead to recovery as per law.
Guidelines clarify recovery proceedings in cases where first appeal is disposed but taxpayer cannot file further appeal due to non-operation of Appellate Tribunal. Taxpayers can make pre-deposit payment through Electronic Liability Register to avail stay on recovery. Undertaking to file appeal when Tribunal operationalizes is required. Amounts paid inadvertently through DRC-03 can be adjusted towards pre-deposit by filing DRC-03A application. Till DRC-03A functionality is available, intimation to proper officer suffices for stay on recovery. Failure to file appeal after Tribunal's operation will lead to recovery as per law.
Note: It is a system-generated summary and is for quick reference only.
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