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 the petitioner liberty to file an appeal before the Additional Commissioner (Appeals II), Chennai, within 30 days of receipt of this order on the condition that the petitioner deposits 50% of the disputed tax in cash as a pre-deposit. Upon such filing and pre-deposit, the Additional Commissioner (Appeals II) is directed to admit and dispose of the appeal on merits after hearing the petitioner, without reference to limitation. If the petitioner fails to comply with the pre-deposit and filing condition, the respondent is at liberty to proceed against the petitioner in accordance with law. Petition disposed of.
The HC granted the petitioner liberty to file an appeal before the Additional Commissioner (Appeals II), Chennai, within 30 days of receipt of this order on the condition that the petitioner deposits 50% of the disputed tax in cash as a pre-deposit. Upon such filing and pre-deposit, the Additional Commissioner (Appeals II) is directed to admit and dispose of the appeal on merits after hearing the petitioner, without reference to limitation. If the petitioner fails to comply with the pre-deposit and filing condition, the respondent is at liberty to proceed against the petitioner in accordance with law. Petition disposed of.
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