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...
Dismissal of an appeal by the petitioner against an assessment order. The dismissal was primarily due to the petitioner filing an online appeal without submitting a certified physical copy of the assessment order, instead providing a downloaded copy. The High Courts unanimously held that the amendment to Rule 108, effective from 26.12.2022, is procedural and retrospective, relying on Indian Potash Ltd. v. Deputy Commissioner and Oaknorth (India) Pvt. Ltd. v. Union of India. The courts agreed that rejecting an appeal on hyper-technical grounds is untenable, especially when filed timely with a downloaded copy. Consequently, the impugned appellate order was set aside, the appeal restored to the appellate authority for a merit-based decision in accordance with the law.
Dismissal of an appeal by the petitioner against an assessment order. The dismissal was primarily due to the petitioner filing an online appeal without submitting a certified physical copy of the assessment order, instead providing a downloaded copy. The High Courts unanimously held that the amendment to Rule 108, effective from 26.12.2022, is procedural and retrospective, relying on Indian Potash Ltd. v. Deputy Commissioner and Oaknorth (India) Pvt. Ltd. v. Union of India. The courts agreed that rejecting an appeal on hyper-technical grounds is untenable, especially when filed timely with a downloaded copy. Consequently, the impugned appellate order was set aside, the appeal restored to the appellate authority for a merit-based decision in accordance with the law.
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