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...
HC held that the trust's registration under SS12A is undisputed, and despite loss of original SS12AA certificate in 2012, respondent authorities must reconstruct their file and reissue the registration certificate. The court directed respondent to complete certificate reconstruction within 12 weeks, enabling the petitioner to claim tax exemptions under SS11 and SS12 without procedural impediments. The petition was disposed of, mandating administrative compliance to restore the trust's legal documentation and tax benefits.
HC held that the trust's registration under SS12A is undisputed, and despite loss of original SS12AA certificate in 2012, respondent authorities must reconstruct their file and reissue the registration certificate. The court directed respondent to complete certificate reconstruction within 12 weeks, enabling the petitioner to claim tax exemptions under SS11 and SS12 without procedural impediments. The petition was disposed of, mandating administrative compliance to restore the trust's legal documentation and tax benefits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
