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...
Error apparent on record rectified by allowing Revenue's appeal instead of wrongly dismissing it, as logical conclusion of upholding Revenue's contentions. Rectification limited to correcting error on record, not re-hearing matter. Apex Court's guidelines on rectifying apparent errors followed. Request to reconsider monetary limits post-disposal not entertained, as it would reopen decided matters. CESTAT's final order dated 18.03.2024 disposing appeal upheld, no other errors found.
Error apparent on record rectified by allowing Revenue's appeal instead of wrongly dismissing it, as logical conclusion of upholding Revenue's contentions. Rectification limited to correcting error on record, not re-hearing matter. Apex Court's guidelines on rectifying apparent errors followed. Request to reconsider monetary limits post-disposal not entertained, as it would reopen decided matters. CESTAT's final order dated 18.03.2024 disposing appeal upheld, no other errors found.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4801
Join Channel
TaxTMI 
