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...
The High Court directed the respondents to release all refunds due and payable to the petitioner within three weeks, pursuant to the appellate authority's order dated July 4, 2024. This order was issued as the petitioner's statutory appeals and refund claims were inordinately delayed, compelling the petitioner to approach the Court. The Court disposed of the writ petition after the pending appeals pertaining to the relevant tax periods were allowed in the petitioner's favor, rendering no further issues to be adjudicated.
The High Court directed the respondents to release all refunds due and payable to the petitioner within three weeks, pursuant to the appellate authority's order dated July 4, 2024. This order was issued as the petitioner's statutory appeals and refund claims were inordinately delayed, compelling the petitioner to approach the Court. The Court disposed of the writ petition after the pending appeals pertaining to the relevant tax periods were allowed in the petitioner's favor, rendering no further issues to be adjudicated.
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