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 AT accepted the DGAP report in part, finding that the respondent had profiteered Rs. 6,88,770 for the period 27.07.2018-31.10.2018 and directed the respondent to deposit that profiteered amount into the Consumer Welfare Fund, to be apportioned equally between the Centre and States. The Tribunal held that the statutory provision imposing interest at 18% on profiteered amounts is not applicable retrospectively; it operates only from the date the amending rule came into force (post-28.06.2019), and therefore, because the profiteering occurred prior thereto, the respondent was not directed to pay interest. The application was disposed of accordingly.
The AT accepted the DGAP report in part, finding that the respondent had profiteered Rs. 6,88,770 for the period 27.07.2018-31.10.2018 and directed the respondent to deposit that profiteered amount into the Consumer Welfare Fund, to be apportioned equally between the Centre and States. The Tribunal held that the statutory provision imposing interest at 18% on profiteered amounts is not applicable retrospectively; it operates only from the date the amending rule came into force (post-28.06.2019), and therefore, because the profiteering occurred prior thereto, the respondent was not directed to pay interest. The application was disposed of accordingly.
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