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...
Assessment order set aside. Assessing authority to re-do assessment considering amendment. Petitioner allowed to file objections within three weeks. Personal hearing to be granted. Garnishee proceedings related to demand for denial of Input Tax Credit u/s 16(4) for 2017-2018 to be withdrawn. Respondent permitted to continue garnishee proceedings for other demands. Petition disposed.
Assessment order set aside. Assessing authority to re-do assessment considering amendment. Petitioner allowed to file objections within three weeks. Personal hearing to be granted. Garnishee proceedings related to demand for denial of Input Tax Credit u/s 16(4) for 2017-2018 to be withdrawn. Respondent permitted to continue garnishee proceedings for other demands. Petition disposed.
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