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...
Petition challenging assessment order and consequential bank attachment was allowed. Impugned order imposing tax liability on allegation of sale suppression based on purchase-outward supply value difference was set aside. Petitioner claimed unawareness of proceedings due to non-receipt of show cause notice. Considering petitioner's assertion and nature of confirmed tax proposal, reconsideration warranted by remitting 5% of disputed tax demand within two weeks and submitting reply to show cause notice within said period. Petition disposed of.
Petition challenging assessment order and consequential bank attachment was allowed. Impugned order imposing tax liability on allegation of sale suppression based on purchase-outward supply value difference was set aside. Petitioner claimed unawareness of proceedings due to non-receipt of show cause notice. Considering petitioner's assertion and nature of confirmed tax proposal, reconsideration warranted by remitting 5% of disputed tax demand within two weeks and submitting reply to show cause notice within said period. Petition disposed of.
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