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 Appellate Tribunal allowed the appeal and remanded the matter to the adjudicating authority for passing a fresh order. The Tribunal found that the refund claim was erroneously rejected by the lower authorities on the ground of limitation u/s 11B, as there was an inconsistency in treating part of the amount paid as a pre-deposit and the remaining amount differently, despite being of the same nature. The Tribunal set aside the impugned order, holding that the issue required reconsideration by the adjudicating authority.
The Appellate Tribunal allowed the appeal and remanded the matter to the adjudicating authority for passing a fresh order. The Tribunal found that the refund claim was erroneously rejected by the lower authorities on the ground of limitation u/s 11B, as there was an inconsistency in treating part of the amount paid as a pre-deposit and the remaining amount differently, despite being of the same nature. The Tribunal set aside the impugned order, holding that the issue required reconsideration by the adjudicating authority.
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