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...
Challenge to provisional attachment order concerning bank account - pre-show cause notice issued - court held documents seized should be returned as petitioner is in real estate business and requires documents for operations - order of seizure not interfered with but respondents directed to return seized documents - regarding provisional bank attachment orders, in light of petitioner's contention of partial discharge of liability and interim stay by court, attachment orders set aside with liberty to respondents to proceed further after decision on show cause notice - petition partly allowed.
Challenge to provisional attachment order concerning bank account - pre-show cause notice issued - court held documents seized should be returned as petitioner is in real estate business and requires documents for operations - order of seizure not interfered with but respondents directed to return seized documents - regarding provisional bank attachment orders, in light of petitioner's contention of partial discharge of liability and interim stay by court, attachment orders set aside with liberty to respondents to proceed further after decision on show cause notice - petition partly allowed.
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