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 AT upheld FMC's jurisdiction to conduct inquiry into affairs of NMCE and its key management personnel to protect investors' interests. It found payment of Rs. 28.8 crore by NMCE to ATSPL for software development bogus, amounting to embezzlement. Allotment of NMCE shares to appellant No. 2 without following due process was held illegal. Appointment of 144 consultants without due diligence and misappropriation of NMCE funds of over Rs. 60 lakh for personal expenses by appellant No. 1 and family were also upheld as irregularities. The appeals were dismissed.
The AT upheld FMC's jurisdiction to conduct inquiry into affairs of NMCE and its key management personnel to protect investors' interests. It found payment of Rs. 28.8 crore by NMCE to ATSPL for software development bogus, amounting to embezzlement. Allotment of NMCE shares to appellant No. 2 without following due process was held illegal. Appointment of 144 consultants without due diligence and misappropriation of NMCE funds of over Rs. 60 lakh for personal expenses by appellant No. 1 and family were also upheld as irregularities. The appeals were dismissed.
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