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...
Maintainability of petition challenged on different cause of action. Petitioner claimed refund/Input Tax Credit for purchase of goods utilized in manufacturing and export of garments from September 2019 to January 2020. Though Special Appeal pending before Court on writ petition, cause of action different. Writ petition disposed, directing petitioner to approach appellate authority against impugned orders.
Maintainability of petition challenged on different cause of action. Petitioner claimed refund/Input Tax Credit for purchase of goods utilized in manufacturing and export of garments from September 2019 to January 2020. Though Special Appeal pending before Court on writ petition, cause of action different. Writ petition disposed, directing petitioner to approach appellate authority against impugned orders.
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