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 quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
The HC quashed and set aside orders under s.201 for A.Y. 2018-19 and 2019-20, holding them unsustainable because identical issues were earlier quashed for A.Y. 2014-15 and 2016-17 and the AO (TDS) acted without jurisdiction contrary to the Tribunal's decisions; the Revenue's plea of alternate remedy was rejected. The matter is remitted to the AO (TDS) to the stage of issuance of the show-cause notice under s.201 for fresh adjudication after disposal of the pending HC appeal, with all consequential proceedings held infructuous. The Petitioner's undertaking to withdraw statutory appeals before the CIT(A) is accepted, subject to revival if this order is set aside on challenge.
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