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 held that once an appeal by the Revenue is included in the application for settlement under the Direct Tax Vivad Se Vishwas Act, 2020 (VSV Act), all disputes forming the subject matter of that appeal and the potential outcome become subject to closure and discontinuance. The tax liability arising from such appeal sets is governed exclusively by the VSV Act. The issuance of the certificate u/s 5 of the VSV Act renders both appeals closed and all aspects of disputation rendered quietus. The Court rejected the claim for statutory interest u/s 244A of the Income Tax Act. However, it directed the respondents to pay interest at 5% per annum on account of the delay in releasing the amount determined under the VSV Act, for the period between February/November 2021 to February 2023.
The High Court held that once an appeal by the Revenue is included in the application for settlement under the Direct Tax Vivad Se Vishwas Act, 2020 (VSV Act), all disputes forming the subject matter of that appeal and the potential outcome become subject to closure and discontinuance. The tax liability arising from such appeal sets is governed exclusively by the VSV Act. The issuance of the certificate u/s 5 of the VSV Act renders both appeals closed and all aspects of disputation rendered quietus. The Court rejected the claim for statutory interest u/s 244A of the Income Tax Act. However, it directed the respondents to pay interest at 5% per annum on account of the delay in releasing the amount determined under the VSV Act, for the period between February/November 2021 to February 2023.
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