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...
Territorial jurisdiction of CMM assessed. DRT has jurisdiction to determine if secured creditor's enforcement of security is as per Act. CMM has authority to take possession of secured asset within jurisdiction, but impugned order without jurisdiction as property situated outside CMM's territorial limits. Petitioner ought to approach DRT u/s 17 of SARFAESI Act. Impugned order suspended for one week to approach DRT. Petition disposed of.
Territorial jurisdiction of CMM assessed. DRT has jurisdiction to determine if secured creditor's enforcement of security is as per Act. CMM has authority to take possession of secured asset within jurisdiction, but impugned order without jurisdiction as property situated outside CMM's territorial limits. Petitioner ought to approach DRT u/s 17 of SARFAESI Act. Impugned order suspended for one week to approach DRT. Petition disposed of.
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