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...
Challenge to assessment order - time limitation. It is not required to dilate on taxability under GST regime from 01.07.2017. Matter requires consideration on merits. Prayer for quashing cannot be considered. However, balancing interests, impugned orders set aside by remitting cases to pass fresh orders, subject to depositing 10% of disputed tax within 30 days. Petition disposed by way of remand.
Challenge to assessment order - time limitation. It is not required to dilate on taxability under GST regime from 01.07.2017. Matter requires consideration on merits. Prayer for quashing cannot be considered. However, balancing interests, impugned orders set aside by remitting cases to pass fresh orders, subject to depositing 10% of disputed tax within 30 days. Petition disposed by way of remand.
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