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 HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
The HC held that the Tribunal erred in exercising jurisdiction u/s 254(2) to set aside the additions made by the AO regarding delayed payment of statutory dues like PF and ESIC amounts. This view was contrary to the SC's decision in Checkmate Services Pvt Ltd, which was rendered after the Tribunal's order. The HC agreed with the Tribunal's decision in ANI Integrated Services Ltd, which rejected the Revenue's application seeking rectification in light of Checkmate Services Pvt Ltd, considering the limited jurisdiction u/s 254(2) and Beghar Foundation.
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