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...
Invocation of extraordinary writ jurisdiction - petitioner not entitled to exclusion of time taken in writ proceedings from limitation period for filing appeal. Abuse of process of Court - reagitating issue already decided amounts to abuse, relitigation contrary to justice and public policy. Writ petition dismissed as petitioner cannot seek condonation of delay in filing appeal after writ proceedings set aside assessment order, filing appeal to avoid compliance with writ Court's directions is abuse of process.
Invocation of extraordinary writ jurisdiction - petitioner not entitled to exclusion of time taken in writ proceedings from limitation period for filing appeal. Abuse of process of Court - reagitating issue already decided amounts to abuse, relitigation contrary to justice and public policy. Writ petition dismissed as petitioner cannot seek condonation of delay in filing appeal after writ proceedings set aside assessment order, filing appeal to avoid compliance with writ Court's directions is abuse of process.
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