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...
NCLAT upheld CMA's categorization of claims related to delay in possession as "put under adjudication". CMA rightly asserted inability to verify rental claims unilaterally when agreement didn't provide for reimbursement of rent or commitment to pay rent. Claims premised on rental agreements fell under adjudication beyond CMA's limited jurisdiction. Unliquidated damages for delayed delivery and mental agony couldn't be admitted without agreement between parties. Appeal dismissed.
NCLAT upheld CMA's categorization of claims related to delay in possession as "put under adjudication". CMA rightly asserted inability to verify rental claims unilaterally when agreement didn't provide for reimbursement of rent or commitment to pay rent. Claims premised on rental agreements fell under adjudication beyond CMA's limited jurisdiction. Unliquidated damages for delayed delivery and mental agony couldn't be admitted without agreement between parties. Appeal dismissed.
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