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...
Rejection of a compounding application filed beyond the prescribed time limit as per the CBDT circular. The High Court held that the CBDT cannot issue a circular contrary to the object of the provisions, and fixing a time limit for filing a compounding application is not permissible u/s 279(2) of the Income Tax Act. The Court ruled that once an offence is compoundable by law, its compoundability cannot be restricted by imposing a time limit. The impugned order was set aside, and the matter was remanded to the respondent to consider the compounding application on record, as the petitioner was not a habitual offender.
Rejection of a compounding application filed beyond the prescribed time limit as per the CBDT circular. The High Court held that the CBDT cannot issue a circular contrary to the object of the provisions, and fixing a time limit for filing a compounding application is not permissible u/s 279(2) of the Income Tax Act. The Court ruled that once an offence is compoundable by law, its compoundability cannot be restricted by imposing a time limit. The impugned order was set aside, and the matter was remanded to the respondent to consider the compounding application on record, as the petitioner was not a habitual offender.
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