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...
Respondent granted permission to travel abroad to Dubai and Europe by HC subject to conditions. Investigation pending since 06.06.2022 in FIR registered on 13.04.2021, no chargesheet filed. Respondent cooperated with investigating agencies when summoned, disclosed required information. Appellant failed to disclose timeframe for concluding pending investigations. Respondent cannot be deprived of right to travel abroad in such circumstances. No infirmity found in Single Judge's order imposing conditions while granting travel permission. LPA dismissed.
Respondent granted permission to travel abroad to Dubai and Europe by HC subject to conditions. Investigation pending since 06.06.2022 in FIR registered on 13.04.2021, no chargesheet filed. Respondent cooperated with investigating agencies when summoned, disclosed required information. Appellant failed to disclose timeframe for concluding pending investigations. Respondent cannot be deprived of right to travel abroad in such circumstances. No infirmity found in Single Judge's order imposing conditions while granting travel permission. LPA dismissed.
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