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 dismissed the writ challenging a suo motu revision order by an Additional Commissioner under s.23(4)(a) of the OST Act, holding the Additional Commissioner validly exercised delegated revisionary power and that the Commissioner lacked jurisdiction to re-initiate revision once such delegated power was exercised. By virtue of the non-obstante clause in s.23(4)(d) and the delegation scheme under s.3/Rule 3, any remedy lies by way of appeal to the Commissioner under s.23(4)(c)(ii). The petitioner was directed to pursue the statutory appellate remedy against the order dated 31 May 2025 before the Commissioner and may raise all available grounds; the writ petition was disposed.
The HC dismissed the writ challenging a suo motu revision order by an Additional Commissioner under s.23(4)(a) of the OST Act, holding the Additional Commissioner validly exercised delegated revisionary power and that the Commissioner lacked jurisdiction to re-initiate revision once such delegated power was exercised. By virtue of the non-obstante clause in s.23(4)(d) and the delegation scheme under s.3/Rule 3, any remedy lies by way of appeal to the Commissioner under s.23(4)(c)(ii). The petitioner was directed to pursue the statutory appellate remedy against the order dated 31 May 2025 before the Commissioner and may raise all available grounds; the writ petition was disposed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
