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...
Seizure of documents, books, laptops, CPUs, mobile phones permissible u/s 67(2) CGST Act but must be returned within 30 days of issuing notice as per Section 67(3) unless required for proceedings. HC directed Commissioner to provide copies of seized data to petitioners and examine providing additional hard disks for data copy. Matter listed for further hearing.
Seizure of documents, books, laptops, CPUs, mobile phones permissible u/s 67(2) CGST Act but must be returned within 30 days of issuing notice as per Section 67(3) unless required for proceedings. HC directed Commissioner to provide copies of seized data to petitioners and examine providing additional hard disks for data copy. Matter listed for further hearing.
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