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...
State tax department directs strict procedures for assessing whether to file appeals or revisions against appellate tribunal orders that prejudice revenue, requiring assessing and intelligence officers to scrutinize orders for erroneous decisions or unresolved questions of law, prepare fact-based, reasoned remarks, obtain in-house legal views where needed, and submit those remarks to supervisory Joint Commissioners for second-level evaluation before transmission to the Joint Commissioner (Law). Remarks must include a concise order summary, legal evaluation emphasizing error or question of law, and a reasoned recommendation on appeal; approved revisions will be monitored through the court process. These instructions take immediate effect.
State tax department directs strict procedures for assessing whether to file appeals or revisions against appellate tribunal orders that prejudice revenue, requiring assessing and intelligence officers to scrutinize orders for erroneous decisions or unresolved questions of law, prepare fact-based, reasoned remarks, obtain in-house legal views where needed, and submit those remarks to supervisory Joint Commissioners for second-level evaluation before transmission to the Joint Commissioner (Law). Remarks must include a concise order summary, legal evaluation emphasizing error or question of law, and a reasoned recommendation on appeal; approved revisions will be monitored through the court process. These instructions take immediate effect.
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