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 a partial stay of the impugned order blocking electronic credit ledger, limiting relief to 50% of the petitioner's assessed tax liability of Rs. 23,75,480 (i.e., Rs. 11,87,740). The negative blocking of Rs. 48,93,551 remains but is reduced effectively to Rs. 37,05,811 pending further consideration; the petitioner is authorized to debit Rs. 11,87,740 from the blocked credit and must replenish the full blocked amount of Rs. 48,93,551 before the next tax payment due date. The negative blocking shall continue until filing of the next monthly return and payment or until an order under Rule 86(2) or Rule 86A supersedes it. Petition disposed.
The HC granted a partial stay of the impugned order blocking electronic credit ledger, limiting relief to 50% of the petitioner's assessed tax liability of Rs. 23,75,480 (i.e., Rs. 11,87,740). The negative blocking of Rs. 48,93,551 remains but is reduced effectively to Rs. 37,05,811 pending further consideration; the petitioner is authorized to debit Rs. 11,87,740 from the blocked credit and must replenish the full blocked amount of Rs. 48,93,551 before the next tax payment due date. The negative blocking shall continue until filing of the next monthly return and payment or until an order under Rule 86(2) or Rule 86A supersedes it. Petition disposed.
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