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 granted partial relief to the petitioner by allowing operation of the frozen bank account, subject to the condition that the existing balance exceeding Rs. 6.00 Crores remain untouched until the CIT(A) disposes of the appeal within six weeks. The petitioner may deposit additional funds and withdraw those amounts for business purposes. The court directed the CIT(A) to expeditiously adjudicate the appeal in accordance with law, balancing the petitioner's operational needs against the Revenue's claim. This interim order preserves the status quo on the substantial existing funds while enabling limited liquidity to prevent business paralysis.
The HC granted partial relief to the petitioner by allowing operation of the frozen bank account, subject to the condition that the existing balance exceeding Rs. 6.00 Crores remain untouched until the CIT(A) disposes of the appeal within six weeks. The petitioner may deposit additional funds and withdraw those amounts for business purposes. The court directed the CIT(A) to expeditiously adjudicate the appeal in accordance with law, balancing the petitioner's operational needs against the Revenue's claim. This interim order preserves the status quo on the substantial existing funds while enabling limited liquidity to prevent business paralysis.
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