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...
Taxpayer company availed amnesty scheme benefit, deposited tax amount, but failed to communicate timely due to COVID-19 pandemic and consultant's death. HC quashed revenue's order denying amnesty benefit, directed granting full benefit by accepting deposited tax amount as final settlement for the year, considering pandemic situation and limitation extension by Supreme Court order.
Taxpayer company availed amnesty scheme benefit, deposited tax amount, but failed to communicate timely due to COVID-19 pandemic and consultant's death. HC quashed revenue's order denying amnesty benefit, directed granting full benefit by accepting deposited tax amount as final settlement for the year, considering pandemic situation and limitation extension by Supreme Court order.
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