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...
Petitioner deposited amount under alleged coercion and protest, claiming inadmissible Input Tax Credit availed. Respondent disputed coercion, stating voluntary deposit. Court observed deposits not made during raid or custody, but under alleged threat of cancellation of registration. Petitioner could have availed remedies against such threats. Court deemed enquiry into coercion or voluntary deposit unnecessary, noting petitioner can seek refund if excess tax deposited, in accordance with law. Petition disposed of.
Petitioner deposited amount under alleged coercion and protest, claiming inadmissible Input Tax Credit availed. Respondent disputed coercion, stating voluntary deposit. Court observed deposits not made during raid or custody, but under alleged threat of cancellation of registration. Petitioner could have availed remedies against such threats. Court deemed enquiry into coercion or voluntary deposit unnecessary, noting petitioner can seek refund if excess tax deposited, in accordance with law. Petition disposed of.
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